tag:blogger.com,1999:blog-5688599Mon, 19 Mar 2018 17:26:09 +0000policyspectrumhard-intangiblesICTinterferencefccregulationfactoidspoetrymetaphorpoliticsreceiverscognitionInterference-Limitscomplexitywirelessgovernanceprogrammingsharingcultureharm-claim-thresholdsradiorisk-assessmentcellularcommunicationseconomicsTVmediafinancephilosophyunlicensedNodeXLadjudicationmeditationprivacyproperty-rightstrendswhitespaces3.5GHzMicrosoftOfcomPCASTastronomyauctionsciscocomputinghealthhungerinternetlawmetricsreligionsatellitesciencesecuritysocialnetworkstransparencywordsworst-case5G800MHzAWS-4CongressDoDETSIEUEuropean-UnionFacebookGPSGoogleQualcommRF-noiseSNApshotairlineallocationanalogyaviationbogglebroadbandcharityclassificationconferencecongestionconsciousnessdatabasesderegulationdesigndronesefficiencyenergyenforcementethicsgardeninggeographyguard-bandshypnosisinternationallearningmapsmathsmobilemodelingmulti-stakeholdermusicnet-neutralityplacebopovertyprecautionary-principlepropagationpsychologyresearchresililiencerevolutionrulemakingscientific-methodsensorsstandardsterminologyterraintestimonytwitterusvisualizationweb2.0writingDeep Freeze 9"I suspect that whatever cannot be said clearly is probably not being thought clearly either" --- Peter Singer. (Mea culpa.) See the <u><a href="http://quotesjournal.blogspot.com/2016/10/i-suspect-that-whatever-cannot-be-said.html">entry</a></u> in my <u><a href="http://quotesjournal.blogspot.com">Quotes</a></u> blog.https://deepfreeze9.blogspot.com/noreply@blogger.com (Pierre de Vries)Blogger562125tag:blogger.com,1999:blog-5688599.post-4912248216704993720Mon, 19 Mar 2018 17:26:00 +00002018-03-19T10:26:09.760-07:00interferencemulti-stakeholderrisk-assessmentsatelliteManaging next-generation satellite interferenceBig-time spectrum sharing is coming to space operations. There may soon be thousands of satellites, from half a dozen or more operators, operating in the same bands, at the same time, flashing in and out of interfering alignments as they crisscross the sky. These planned non-GSO (non-geostationary orbit) deployments bring unprecedented complexity to the space business.<br /><br />The satellite industry needs new ways to assess the risk of interference, identify which mitigations and regulations would be most effective, and work together to avoid interference. I’ll describe two of them: risk-assessment and multi-stakeholder coordination.<br /><br /><b>Situation</b><br /><br /><div><div>The satellite game is changing in at least three ways.</div><div><br /></div><div>First, the planned non-GSO constellations will increase the number of objects in LEO and MEO (low- and medium-Earth orbit, respectively) by at least a factor of ten. For example, if just SpaceX completes its planned deployment, it will add more than 11,000 satellites to the 1,070 LEO objects recorded in the UCS database as of August 2017. OneWeb’s planned 1,280 MEO constellation is more than ten times the 97 MEO objects counted by the UCS.</div><div><br /></div><div>Second, there’s increasing diversity of competitors in the satellite business. Billions of dollars are being invested in NewSpace start-ups. There are new launch companies like SpaceX, Blue Origin and Rocket Lab; new entrants like OneWeb, SpaceX, Boeing and Telesat planning to compete against existing non-GSO services from Iridium and SES-O3b; a burgeoning number of companies offering earth observation (Planet, Spire, Theia, etc.) as well as ancillary in-orbit communications services (LeoSat, Audacy); and last but not least, GSO operators are deploying a new generation of high-throughput satellites.</div><div><br /></div><div>Third, the competitive landscape is getting more complicated. There are worries about over-capacity, as a new generation of GSO satellites increase per-satellite throughput dramatically. GSO players are fighting to protect their investments against commercial and interference encroachment from non-GSO systems. For their part, the non-GSO systems compete against each other not just for customers, but also in mitigating interference between systems with very different orbits. And that doesn’t even address the non-satellite competitors: terrestrial cellular coverage is spreading ever deeper into rural areas, threatening one of satellite’s key value propositions, and new technologies like stratospheric drones and balloons may compete in earth observation services as well as delivering rural broadband.</div><div>There is a lot of uncertainty. Nobody’s sure which non-GSO systems will make it into orbit; the only certainty seems to be that not all the currently proposed systems will fly. Opinions about the profitability of non-GSO constellations range from optimism to profound skepticism. We don’t know how much inter-operator coordination will be needed to avoid harmful interference. It might be none, or it might be a lot – and it’ll depend on who makes it to orbit. Even if no coordination is required, there’s uncertainty about which interference risk mitigations – such as narrow antenna beams or transmit power limits – will be needed.&nbsp;</div></div><div><br /></div><div><div><b>Risk-Informed Interference Assessment</b></div><div><br /></div><div><i>Need</i></div><div><br /></div><div>Avoiding harmful interference between satellite constellations – some with thousands of satellites, at lots of altitudes, some moving rapidly across a user’s field of view – is complex. Different constellations, e.g. low vs medium earth orbit, present different risks to each other; the risk depends on operational parameters like orbit, uplink transmit power and antenna beamwidth; and the risk will vary from place to place depending on local conditions (e.g. rain fade) and orbit alignment (e.g. polar vs. equatorial). The high uplink transmit power needed to reach MEO satellites may interfere with LEO; and large LEO constellations may interfere with smaller MEO and highly elliptical constellations. There’s also the underlying uncertainty about which systems will make it into orbit, multiplying the number of interactions to model.</div><div><br /></div><div>Nobody’s sure what measures will be needed (if any) to ensure that these non-GSO systems can coexist without degrading each other’s throughput. The risk of interference – in the absence of mitigation – could be negligible, or it could be substantial, at least for some configurations. Mitigation adds cost and complexity, but there is little published information on the quantitative risk of inter-service degradation, let alone on the cost-benefit trade-offs between different mitigation strategies.</div><div><br /></div><div>We need new ways to think about managing inter-system interference given all these uncertainties. Quantitative risk assessment, a mature technique used by just about every regulated industry except wireless, shows promise as a spectrum management tool.</div><div><br /></div><div><i>Definitions</i></div><div><br /></div><div>Engineering risk is the likelihood and consequence of potential sources of harm (aka hazards). Risk combines probability with severity. For example, I live in the Seattle area, and the hazard is getting wet. The risk is not just the probability of rain (likelihood), but also whether it’s a drip or a downpour (consequence). Weather forecasts often provide both the probability of rain and number of inches expected – that’s a risk assessment.</div><div><br /></div><div>Risk assessment can be compared to worst-case analysis, which is frequently used in spectrum studies. Worst-case focuses on the single hazard with the highest perceived severity, regardless of likelihood. It’s just one scenario – a corner case – that doesn’t help one to make complex trade-offs between permutations of operating variable values.</div><div><br /></div><div><i>Risks and mitigations</i></div><div><br /></div><div>The dominant inter-constellation interference hazard is co-channel operation on overlapping paths between earth stations and satellites, aka in-line events. These events can occur when a ground transmitter’s beam illuminates a space receiver from another constellation that’s in the line between the ground and the intended receiver; or when two ground receivers close to each other are looking at respective space transmitters that are in the same direction. Other risks include adjacent channel interference, and interference between earth stations, or between space stations. There are also baseline hazards even without interference, including degradation of the desired signal (e.g. due to atmospheric attenuation), and non-interference faults and failures like misconfiguration, hardware faults, and operator error.&nbsp;</div><div><br /></div><div>There are many possible mitigations. For example, look-aside: if a constellation has multiple satellites visible simultaneously, its ground transmitter could point to a space receiver that’s not in-line with a receiver from another constellation, so avoiding interference. This would also work on the downlink, where ground receivers close to each other look in different directions and reject interfering signal due to high antenna gain. If this isn’t possible (say because satellite paths that aren’t in-line aren’t available, or operators of two constellations haven’t agreed on how to point in different directions) then systems can split the band – one constellation uses the lower half, say, and the other the upper half.</div><div><br /></div><div><i>Benefits</i></div><div><br /></div><div>Risk-Informed Interference Assessment can improve system design by showing which elements are most important, integrating information from many sources, including historical data, expert intuition, understanding of system behavior, and modeling. It allows one to challenge assumptions and reveal misconceptions, correcting misplaced optimism or pessimism. One could explore the key vulnerabilities of different kind of satellite architectures, i.e. LEO vs. MEO, and large vs. small constellations. Operators argue before the FCC about who’s the bigger victim –it could be both, depending on the circumstance, e.g. downlink vs. uplink.</div><div><br /></div><div>It can also help to compare the relative risk of degradation under various assumptions for everything from the number of satellites to the out-of-band emission mask. For example, which system parameters have the biggest impact on interference risk: the number of satellites or ground stations, altitude of a constellation, antenna gain, uplink transmit power, out-of-band emission mask, receiver selectivity, and/or something else? Similarly, one could explore which mitigation techniques offer the most leverage: band splitting, look-aside, align channels, adaptive links, or something else? Mitigation adds complexity, which generates operating error hazards; it’s also costly. Is mitigation in fact needed, or is it money spent to avoid interference that doesn’t occur? RIIA can thus be used to assess what mitigation technologies or operating rules would be most effective. Is an incremental dollar (or kilogram, or watt) better spent on antenna gain or more sophisticated in-line avoidance? If the modeled risks are sufficiently low, the community might decide to trigger inter-operator coordination by observed performance degradation, rather than trying to prevent putative low-risk hazards in advance.</div></div><div><br /></div><div><div><b>Multi-stakeholder processes</b></div><div><br /></div><div>As more non-GSO satellite constellations become operational, the industry’s customary approach of avoiding interference through bi-lateral coordination becomes more challenging. With three players, there are three bi-lateral relationships; but with six players, there are fifteen bi-laterals. A dozen companies have applied to the FCC to operate a non-GSO constellation in the Ku/Ka-band.</div><div>Some sort of multi-stakeholder process seems to be necessary. However, the satellite industry hasn’t had much success with multi-stakeholder arrangements beyond ITU-R study groups, and satellite operators prefer proprietary solutions over industry standards. This is in stark contrast to the terrestrial wireless industry, where global standards bodies like the 3GPP and IEEE, and trade associations like the CTIA, GSMA and Wi-Fi Alliance are a fixture.&nbsp;</div><div><br /></div><div>The loner approach makes sense when interference problems are relatively simple, and low equipment volumes don’t justify the cost of global standardization. But both conditions are changing for satellites: avoiding interference between many independent constellations appears to be quite complex, and satellite constellation business models only make sense if device volumes are large.&nbsp;</div><div>Experience in other industries suggests that sharing data is essential for risk reduction, and that industry forums are a good way to do this. For example, after the Piper Alpha oil-rig disaster in the North Sea, Norway required probabilistic risk assessments. This necessitated compiling data on component failure rates, but operators were unwilling to share company-confidential information with each other. This led to the creation of a 3rd party database; as an incentive to participate, data contributors got free access, while non-contributors had to pay. This database not only reduced risk, but also reduced operating costs since data on part failure increased reliability.&nbsp;</div><div><br /></div><div>Sharing satellite operating data may be necessary, and will be helpful, in reducing the risk of orbital collisions and harmful interference. Several satellite-related multi-stakeholder groups already exist, though one can debate their suitability to host a non-GSO coordination multi-stakeholder group. One candidate is the SDA (Space Data Association), a non-profit international association of satellite operators that works towards sharing safety-critical data about the space environment and the RF spectrum. ITU groups such as the SFCG (Space Frequency Coordination Group) and professional bodies like the AIAA (American Institute of Aeronautics and Astronautics) may also have a role to play.</div><div><br /></div><div><b>Synthesis</b></div><div><br /></div><div>While risk-informed interference assessment and multi-stakeholder processes are helpful on their own, they’re better together. A multi-stakeholder organization provides a forum for engineers to hammer out rough consensus on the base assumptions for risk assessments. The computer modeling that follows can then inform community decisions about which mitigation techniques to focus on, and when.&nbsp;</div><div><br /></div><div>This synergy is like the virtuous circle of "rough consensus and running code" pioneered at the IETF by internet engineers interested in practical, working systems that can be quickly implemented. The satellite business is speeding up and spreading out. The rich decision support and agility provided by risk assessment and multi-stakeholder collaboration will soon be a competitive advantage and may become essential to success.</div></div><div><br /></div><div><br /></div><div><br /></div>https://deepfreeze9.blogspot.com/2018/03/managing-next-generation-satellite.htmlnoreply@blogger.com (Pierre de Vries)0tag:blogger.com,1999:blog-5688599.post-2259601640327950901Sat, 24 Feb 2018 23:58:00 +00002018-03-19T10:18:11.857-07:00harm-claim-thresholdsinterferenceInterference-LimitsRF-noisespectrumIs harmful radio interference decreasing?Spectrum analysts (including me) often proclaim that harmful interference is a growing problem, or at the very least a growing risk. That sounds plausible, given the growing profusion of radios, packed more and more densely together. But what if the opposite is true?<br /><br /><a name='more'></a>Data on interference trends are hard to come by. Anecdotes abound, and published information usually covers just narrow slivers of time, space and frequency. The FCC doesn’t publish comprehensive data on interference incidents, in spite of repeated calls to do so. (It does publish <a href="https://www.fcc.gov/general/amateur-radio-service-enforcement-actions" target="_blank">a non-comprehensive list of Amateur Radio Service enforcement actions</a>, but at the time of writing it covers only 2009–2016. FWIW, the number of RFI incidents reported by amateurs is flat over this period.) When the FCC’s panel of technical advisors (the TAC) launched <a href="https://www.fcc.gov/ecfs/search/filings?proceedings_name=16-191&amp;sort=date_disseminated,DESC" target="_blank">a formal inquiry</a> in 2016 to find out whether there was an increase in background radio noise, many commenters pointed at data, but nobody offered a thorough analysis. The TAC didn’t come to any firm conclusions about whether radio noise was increasing or not.<br /><br />The perception of increasing harmful interference is skewed by cognitive biases. There is certainly selection bias: for example, the people who file comments about a rise in radio noise are predominantly the ones that believe there’s a rise in radio noise. Since we tend to over-estimate the likelihood of events which are recent, unusual or emotionally charged, availability bias also plays a role: striking stories about exceptional interference sway our judgment. And last but not least, there’s confirmation bias: once we’ve taken a position – that harmful interference is getting worse, for example – we’re likely to search out, focus on, remember and interpret data in a way that confirms our preconceptions.<br /><br />The obvious null hypothesis is that the incidence of harmful interference isn’t changing in either direction. However, experience with other technologies suggests that the most plausible hypothesis is that it’s probably declining &nbsp;– in spite of lamentations to the contrary.<br /><br />For example, consider car accidents in the United States (<a href="https://en.wikipedia.org/wiki/Motor_vehicle_fatality_rate_in_U.S._by_year" target="_blank">Wikipedia</a>). The US population more than doubled from 127 million in 1935 to 321 million in 2015, and the number of vehicle miles traveled (VMT) increased more than tenfold from 229 billion to 3,095 billion per year. However, the total number of road deaths stayed flat (34,494 in 1935 and 35,485 in 2015), and the number of fatalities per mile driven decreased tenfold from 15.09 to 1.15 per 100 million VMT.<br /><br /><div class="separator" style="clear: both; text-align: center;"><a href="https://commons.wikimedia.org/wiki/File:US_traffic_deaths_per_VMT,_VMT,_per_capita,_and_total_annual_deaths.pngg" imageanchor="1"><img alt="" border="0" data-original-height="487" data-original-width="800" height="387" src="https://1.bp.blogspot.com/-u1usLg6maRo/WpH4lksp8aI/AAAAAAAAAi0/LJ6DFJ6OAukFG3t3HxExH4Wjsms7_jp-QCLcBGAs/s640/800px-US_traffic_deaths_per_VMT%252C_VMT%252C_per_capita%252C_and_total_annual_deaths.png" title="" width="640" /></a></div>(Image source: Dennis Bratland,&nbsp;CC BY-SA 4.0, <a href="https://en.wikipedia.org/wiki/Motor_vehicle_fatality_rate_in_U.S._by_year#/media/File:US_traffic_deaths_per_VMT,_VMT,_per_capita,_and_total_annual_deaths.png" target="_blank">link</a>.)<br /><br />There are <a href="http://www.iihs.org/iihs/sr/statusreport/article/50/1/1" target="_blank">many reasons</a> for this. Improved vehicle safety, i.e. technology like crumple zones and anti-lock brakes, played a major role in reducing fatal collisions – that is, in reducing “harmful interference” between vehicles.<br /><br />Wireless technology has also improved dramatically over the last few decades, and those improvements have made radios less vulnerable to interference. Examples include transmitters leaking less interference outside their transmit bands, receivers that are more resistant to interference, and more-directional antennas that only accept signals from desired directions. Hence, it’s reasonable to expect that there is less harmful interference today than there was in the past.<br /><br />Regulation – such as requiring seat belts, and better enforcement of drunk-driving laws – also played a role in reducing automobile fatalities. By comparison, there have been few new regulatory mandates to improve interference-rejection by radios. (The EU Radio Equipment Directive’s receiver requirements are the exception that proves the rule.) Limits on transmitter leakage have hardly changed, and there are effectively no requirements on receiver performance. I don’t believe government-mandated receiver standards are the solution, though industry standards encouraged by government, such the new ETSI receiver standards, may improve matters. I prefer technology neutral ways to incentivize receiver performance, like harm claim thresholds; one automotive comparison is the U.S. Corporate Average Fuel Economy (CAFE) standards, where the government sets targets for average fleet fuel economy without telling manufacturers how to meet them.<br /><br /><b>So what if harmful interference is going down?</b><br /><br />First, we might worry less about predictions of spectrum crisis. Technology improvements seem to have allowed enormous radio densification without coexistence crises. Regulators could probably be more aggressive about cheek-by-jowl sharing arrangements, and more skeptical about incumbents’ claims that new arrangements will cause catastrophe.<br /><br />Second, the success of the wireless community in avoiding a spectrum meltdown without stringent harm-avoidance rules and enforcement on both device performance and user behavior – such as in the automotive sector – suggests that light-touch regulation may be sufficient for wireless. (Whether this is indeed so, and why, is an interesting research problem.)<br /><br />Third, even if the radio noise floor is going up, the risk of harmful interference may be constant or going down because systems are more interference tolerant. The glass-half-full implication is that we needn’t worry about the noise floor. The glass-half-empty interpretation is that our technologies are hiding a growing problem that may suddenly emerge with irreversible force, like <a href="https://www.fool.com/investing/2017/10/30/what-were-the-tipping-points-that-set-off-the-grea.aspx" target="_blank">market crashes</a>, the <a href="http://www.pnas.org/content/115/4/635" target="_blank">eutrophication of lakes</a>, and other tipping points in complex systems.<br /><div><br /></div><div><br /></div><b>Notes</b><br /><br /><i>What's "interference"?</i><br /><br />Some readers might be wondering: if the number of transmitters is going up, doesn’t interference necessarily increase? No – not if one uses the regulatory definition of interference as the effect of unwanted energy, rather than the engineering notion of interference as unwanted energy per se.<br /><br />Here are the regulatory definitions of interference given in the FCC rules, <a href="https://www.law.cornell.edu/cfr/text/47/2.1" target="_blank">47 CFR 2.1</a>, which echo the ITU Radio Regulations (RR) and the annex to the ITU Constitution (CS):<br /><blockquote class="tr_bq"><i>Interference</i>. The <u>effect of unwanted energy</u> due to one or a combination of emissions, radiations, or inductions upon reception in a radiocommunication system, manifested by any performance degradation, misinterpretation, or loss of information which could be extracted in the absence of such unwanted energy. (RR)</blockquote><blockquote class="tr_bq"><i>Harmful Interference</i>. Interference which endangers the functioning of a radionavigation service or of other safety services or seriously degrades, obstructs, or repeatedly interrupts a radiocommunication service operating in accordance with [the ITU] Radio Regulations. (CS)</blockquote><br /><i>Other technology precedents</i><br /><br />One can multiply examples of other technologies where rates of harm have declined even as usage has increased. Take aircraft safety, as reported in <a href="https://www.economist.com/blogs/graphicdetail/2014/03/daily-chart-6" target="_blank">The Economist</a>:<br /><br /><div class="separator" style="clear: both; text-align: center;"><a href="https://2.bp.blogspot.com/-nfz0CJZ657s/WpH7BS8usPI/AAAAAAAAAjM/4fVaAFEI7e4Ia4Hl5qLcS6UnxMqTgl57gCLcBGAs/s1600/Economist%2B20140315_gdc500_0.png" imageanchor="1" style="margin-left: 1em; margin-right: 1em;"><img border="0" data-original-height="474" data-original-width="640" height="472" src="https://2.bp.blogspot.com/-nfz0CJZ657s/WpH7BS8usPI/AAAAAAAAAjM/4fVaAFEI7e4Ia4Hl5qLcS6UnxMqTgl57gCLcBGAs/s640/Economist%2B20140315_gdc500_0.png" width="640" /></a></div><br /><div class="separator" style="clear: both; text-align: center;"></div><br /><br />For air pollution, this image from a recent <a href="https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/681445/Emissions_of_air_pollutants_statistical_release_FINALv4.pdf" target="_blank">statistical release</a> by by UK Department for Environment, Food &amp; Rural Affairs is instructive:<br /><br /><div class="separator" style="clear: both; text-align: center;"><a href="https://4.bp.blogspot.com/-MLkXia9mW4M/WpH7_IHzVnI/AAAAAAAAAjY/0OFrLcxsm3IldPu_3a_pn0m7RNQ-_3-agCLcBGAs/s1600/DEFRA%2BCapture.PNG" imageanchor="1" style="margin-left: 1em; margin-right: 1em;"><img border="0" data-original-height="732" data-original-width="890" height="524" src="https://4.bp.blogspot.com/-MLkXia9mW4M/WpH7_IHzVnI/AAAAAAAAAjY/0OFrLcxsm3IldPu_3a_pn0m7RNQ-_3-agCLcBGAs/s640/DEFRA%2BCapture.PNG" width="640" /></a></div><br /><br /><div><br /></div>https://deepfreeze9.blogspot.com/2018/02/is-harmful-radio-interference-decreasing.htmlnoreply@blogger.com (Pierre de Vries)0tag:blogger.com,1999:blog-5688599.post-5500325361697708715Thu, 22 Feb 2018 17:43:00 +00002018-02-22T09:49:24.398-08:00broadbandsatelliteConstellation satellite broadband: the first shoe dropsI’ve never been convinced about the business model for satellite constellation broadband. However much smarter (and much, much richer) people than me have invested billions in these businesses.<br /><br />SpaceX’s behavior will be a useful leading indicator for this sector, since I think Elon Musk sees broadband as a cash cow to fund his Mars mission. If SpaceX deployment lags or slows, it’ll be a good sign that NGSO broadband isn’t a good business.<br /><br />A <a href="https://www.wsj.com/articles/spacex-indicates-satellite-based-internet-system-will-take-longer-than-anticipated-1519227620" target="_blank">story</a> in today’s WSJ is an early sign of bad news: “SpaceX Throttles Back Broadband Hopes --- Fast global internet likely to take longer than anticipated”. Some highlights:<br /><br />“Acknowledging there are no final cost estimates or engineering designs yet for its proposed broadband constellation, spokesman John Taylor revealed<span style="background-color: #fff2cc;"> substantial delays from initial project timelines</span>. [The] company signaled that development of its high-profile satellite network has been significantly slower -- and seemingly more complex -- than many inside and outside SpaceX originally anticipated.”<br /><br />“SpaceX said in Tuesday night's statement, "we still have considerable technical work ahead of us to design and deploy" some 4,400 similar satellites. <span style="background-color: #fff2cc;">The tentative goal of starting limited service by 2020 now appears unrealistic</span> based on that language, but the company didn't provide an alternate schedule.”<br /><br />“SpaceX engineers are still considering the most appropriate and cost-effective space and ground technologies to embrace, <span style="background-color: #fff2cc;">without firming up subcontractors or completing production plans</span>.”<br /><br />“… <span style="background-color: #fff2cc;">technical and financial details of anticipated ground equipment</span> for subscribers -- considered critical elements in any such project -- are <span style="background-color: #fff2cc;">still undetermined</span>.”<br /><div><br /></div>https://deepfreeze9.blogspot.com/2018/02/constellation-satellite-broadband-first.htmlnoreply@blogger.com (Pierre de Vries)0tag:blogger.com,1999:blog-5688599.post-5856060116976908514Sun, 21 May 2017 18:30:00 +00002017-05-22T08:16:14.169-07:00gardeningprecautionary-principleregulationPermissionless Innovation, the Precautionary Principle, and GardeningAdam Thierer’s insights about “soft law” being the middle ground between permissionless innovation and the precautionary principle reminded me of Michael Pollan’s portrayal of gardening as mediating between the wilderness ethic and humans micromanaging nature.<br /><br /><a name='more'></a>In <a href="https://techliberation.com/2017/05/18/does-permissionless-innovation-even-mean-anything/" target="_blank">his remarks</a> at this year’s <a href="http://conferences.asucollegeoflaw.com/get2017/" target="_blank">GET conference</a> at ASU, Thierer explores the relevance of the term “permissionless innovation” to the governance of emerging technologies. &nbsp;He provides a good description (not surprising, since he’s written <a href="https://www.mercatus.org/publication/permissionless-innovation-continuing-case-comprehensive-technological-freedom" target="_blank">a book</a> about it), notes the apparent contrast with the “precautionary principle,” and then points out some of their shared shortcomings.<br /><br />He concludes that “<span style="background-color: #fff2cc;">all roads lead back to soft law solutions</span> instead of hard law remedies.” He mentions his review of Wendell Wallach’s <a href="http://wendellwallach.com/wordpress/books/dangerous-master/" target="_blank">2015 book</a>, and notes that, “although we do not begin in the same place philosophically-speaking, we largely end up in the same place practically-speaking.”<br /><blockquote class="tr_bq">(According to USLegal.com, “Soft law refers to rules that are neither strictly binding in nature nor completely lacking legal significance. In the context of international law, soft law refers to guidelines, policy declarations or codes of conduct which set standards of conduct. However, they are not directly enforceable.” Thierer identifies it with “multistakeholder processes, and various other informal governance mechanisms will need to fill the governance gap left by the gradual erosion of hard law.”)</blockquote>It reminded me of <a href="http://dx.doi.org/10.2139/ssrn.1229482" target="_blank">my musings</a> about internet governance as forestry. I was inspired by Michael Pollan’s book "<a href="http://michaelpollan.com/reviews/second-nature/" target="_blank">Second Nature</a>," which argues that gardening lies between leaving it to nature, and total control. Looking back, I’m again struck by the power of the regulation-is-gardening metaphor. I can’t say it better than Pollan, so here are a few excerpts:<br /><blockquote class="tr_bq">“The trick, I realize now, is somehow to find a middle ground between these two positions [of laissez-faire and total control]. And that is what a garden is, or should be: a midspace between Dudleytown [an abandoned nineteenth-century settlement near Pollan’s place that had reverted to wilderness] and the parking lot, a place that admits of both nature and human habitation. But it is not, as I had imagined, a harmonious compromise between the two, nor is it stable; from what I can see, it requires continual human intervention or else it will collapse. <span style="background-color: #fff2cc;">The question for the gardener—and in a way it's a question for all of us—is, What is the proper character of that intervention?</span>”</blockquote>Near the end of the book, Pollan makes an explicit analogy between Nature and the Market: “Indeed, the wilderness ethic and laissez-faire economics, antithetical as they might at first appear, are really mirror images of one another. <span style="background-color: #fff2cc;">Each proposes a quasi-divine force—Nature, the Market—that, left to its own devices, somehow knows what’s best for a place</span>.” He argues that the nature/culture dichotomy is misconceived:<br /><blockquote class="tr_bq">“A society that produces "gardens" (or "anti-gardens”) like Central park is one that assumes nature and culture are fundamentally and irreconcilably opposed. And it seems to me that in order to design true gardens of distinction one must have a vision of how the two can harmonized. It may be this that we lack. Americans have historically tended to regard nature as a cure for culture, or vice versa. Faced with the question of what to do with the land, we always seem to come up with the same crude alternatives: to virtuously subdue it in the name of "progress," or to place it strictly off-limits in "wilderness areas," hallowed places we go seeking an antidote to city life.”</blockquote>After a description of the conflict in his little community about whether and how to respond to a storm’s destruction of a revered local pine forest, which pitted “let nature take its course” against “remake it exactly as it was,” he comes to what—to me—is the theme of the book, and the lesson for regulation<br /><blockquote class="tr_bq">“But as far apart as the two sides seemed to stand, they actually shared ground than they realized. Both started from the premise that man and nature were irreconcilably opposed, and that the victory of one necessarily entailed the loss of the other. Both sides, in other words, accepted the premises of what we might call the "wilderness ethic," which is based on the assumption that the relationship of man and nature resembles a zero-sum game. … Watching my little local debate unfold over the course of the summer, and grow progressively more shrill and sterile, I began to wonder if perhaps the wilderness ethic itself, for all that it has accomplished in this country over the past century, had now become part of the problem. I also began to wonder if it might be possible to formulate a different ethic to guide us in our dealings with nature, at least in some places some of the time, <span style="background-color: #fff2cc;">an ethic that would be based not on the idea of wilderness but on the idea of a garden</span>.”</blockquote><blockquote class="tr_bq">“[Forest ecologists and other experts] told me that the classical theory of pine-forest succession probably does describe the underlying tendency at work in Cathedral Pines. But it turns out that a lot can go, if not "wrong" exactly, then at least differently. . . . Nobody, in other words, can say what will happen in Cathedral Pines' And the reason is not that forest ecology is a young or imperfect science, but because nature herself doesn’t know what 's going to happen here. Nature has no grand design for this place.”</blockquote>His comments about gardeners also seem to me to be applicable to wise regulators and policy makers:<br /><blockquote class="tr_bq">“All the accomplished gardeners I know are surprisingly comfortable with failure. They may not be happy about it, but instead of reacting with anger or frustration, they seem freshly intrigued by the peony that, after years of being taken for granted, suddenly fails to bloom. They understand that, in the garden at least, failure speaks louder than success.”</blockquote><blockquote class="tr_bq">“The successful gardener, I’ve found, approaches science and folk wisdom, even magic, with like amounts of scepticism and curiosity. If it works, then it’s “true.” <span style="background-color: #fff2cc;">Good gardeners tend to be flat-out pragmatists not particularly impressed with science</span>.”</blockquote>As a geek, of course, I believe that the FCC could make more use of engineering insights to guide policy; but it good to be reminded why pragmatism is the order of the day.https://deepfreeze9.blogspot.com/2017/05/permissionless-innovation-precautionary.htmlnoreply@blogger.com (Pierre de Vries)0tag:blogger.com,1999:blog-5688599.post-3088678932917314630Tue, 02 May 2017 20:55:00 +00002017-05-02T13:56:18.814-07:00ETSIEUEuropean-UnionreceiversstandardsNote on receivers in the EU Radio Equipment Directive and ETSI standardsThe European Union has focused new attention on radio receiver standards through terms in the Radio Equipment Directive (RED) which came into force last year. The RED’s requirements that any “receiver [must have] a level of performance that allows it to operate as intended and protects it against the risk of harmful interference, in particular from shared or adjacent channels” have been reflected in new ETSI standards.<br /><br /><a name='more'></a><br /><b>The Radio Equipment Directive</b><br /><br />The <a href="http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014L0053&amp;qid=1484267962772&amp;from=en" target="_blank">Radio Equipment Directive 2014/53/EU</a>&nbsp;(OJ L153, 22 May 2014) has been applied in EU Member States since 13 June 2016. It replaces the Radio &amp; Telecommunication Terminal Equipment Directive (<a href="http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:31999L0005&amp;from=EN" target="_blank">RTTED</a>) 1999/5/EC (OJ L91, 7 April 1000) as of that date, and covers equipment that intentionally transmits or receives radio waves for communications or radiodetermination, regardless of primary function.<br /><blockquote class="tr_bq"><br />The citations, e.g. "OJ L153, 22 May 2014," are to the Official Journal of the European Union (OJEU). Directives and other publications in the OJEU can be found via&nbsp;<a href="http://eur-lex.europa.eu/oj/direct-access.html">http://eur-lex.europa.eu/oj/direct-access.html</a>. Take the OJ reference (e.g. for the RED, "OJ L153, 22 May 2014") and select the year and month under "Access by year." For the RED, select 2014 from the dropdown and click May. Then find "L153" in the "L (Legislation)" column; clicking the link will resolve to a page with links to the texts in all the official languages.</blockquote><br />The <a href="http://public.brighttalk.com/resource/core/146387/2017-04-24-etsi-red-webinar-16x9_268667.pdf" target="_blank">ETSI webinar</a> by Michael Sharpe on 27 April 2017 provides a useful overview of the RED and associated ETSI standards.<br /><br />Compared to the RTTED, the RED has an increased emphasis on efficient use of spectrum, in particular by improving radio receiver requirements, and improved provisions for market surveillance and &nbsp;enforcement (in particular between Member States). There is a clear link with the <a href="http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=LEGISSUM:l24218a" target="_blank">Radio Spectrum Decision</a> 676/2002/EC.<br /><br />The RED does not cover<br /><br /><ul><li>Wired telecommunication terminal equipment (product requirements covered by the Low-Voltage Directive (LVD) and Electromagnetic Compatibility Directive (EMCD), and interfaces covered by Directive 2008/63/EC (OJ L162 21.6.2008))</li><li>Equipment exclusively for public security, defense etc.</li><li>Equipment for radio amateurs (unless made available on the market)</li><li>Marine equipment falling under 96/98/EC (Marine Equipment Directive)</li><li>Airborne Products falling under Regulation 216/2008 (EASA Regulation)</li><li>Equipment using radio waves for other purposes (e.g. RF heating, medical imagery...)</li></ul><br />The salient excerpts from the RED regarding receivers are<br /><blockquote class="tr_bq"><i>Whereas…</i></blockquote><blockquote class="tr_bq">(10) “… in the case of a receiver, it has a level of performance that allows it to operate as intended and protects it against the risk of harmful interference, in particular from shared or adjacent channels, and, in so doing, supports improvements in the efficient use of shared or adjacent channels.”&nbsp;</blockquote><blockquote class="tr_bq">(11) “Although receivers do not themselves cause harmful interference, reception capabilities are an increasingly important factor in ensuring the efficient use of radio spectrum by way of an increased resilience of receivers against harmful interference and unwanted signals on the basis of the relevant essential requirements of Union harmonisation legislation.”</blockquote><blockquote class="tr_bq"><i>Article 3&nbsp;</i></blockquote><blockquote class="tr_bq">3.1(b) “1. Radio equipment shall be constructed so as to ensure: (a) …; (b) an adequate level of electromagnetic compatibility as set out in Directive 2014/30/EU.” &nbsp;</blockquote><blockquote class="tr_bq">3.2 “Radio equipment shall be so constructed that it both effectively uses and supports the efficient use of radio spectrum in order to avoid harmful interference.”&nbsp;</blockquote><br />Article 3.2 seems to be taken as a mandate on the performance of receivers.<br /><br /><b>ETSI Standards</b><br /><br />ETSI standards are optional, not mandatory. However, they are very attractive to manufacturers since “[r]adio equipment which is in conformity with harmonised standards [cited in the OJEU]... shall be presumed to be in conformity with the essential requirements...” of the RED (Article 16). Even better, Article 17.3 allows a manufacturer to self-declare conformity to Articles 3.2 and 3.3 if it has applied harmonised standards cited in the OJEU. (Note that the standards must be cited in the OJEU to be valid for self-declaring conformity; publication by ETSI is not sufficient. Since 2015, the Commission must sign off on harmonized standards delivered by ETSI; so far this has always happened, but the review process introduces delay.)<br /><br />Manufacturers have alternative routes, but “EU-type examination” or “conformity based on full quality assurance” both require use of a Notified Body, not just self-certification. For more details, see the&nbsp;European Commission's “<a href="ttps://ec.europa.eu/growth/single-market/european-standards/vademecum_en" target="_blank">Vademecum on European standardization</a>.”<br /><br />Michael Sharpe’s <a href="http://public.brighttalk.com/resource/core/146387/2017-04-24-etsi-red-webinar-16x9_268667.pdf" target="_blank">webinar </a>summarizes ETSI work on harmonized standards to date. Receiver-related highlights include:<br /><br /><ul><li>There are many more products under the scope of RED than were under RTTED, e.g. anything with a GPS receivers is now covered (slide 11)</li><li>A method to characterize UWB receivers has been developed (TS 103 361, slide 25)</li><li>A new version of EN 300 328 (2.45 GHz wideband data transmission systems – Wi-Fi, Bluetooth etc.) is being developed which will inter alia improve receiver performance to reject MFCN in adjacent bands (TS 103 521, slide 24)</li><li>In EN 301 893 (5 GHz Wireless Access Systems / Radio LAN) now specifies receiver blocking requirements to meet the RED (TS 103 521, slide 26)</li><li>There are now standards for terrestrial and satellite TV receivers, and broadcast radio receivers (slide 28)</li><li>Various radars (marine, aeronautical, automotive, meteorological) now subject to standardization (slide 28)</li></ul><br />A lot of effort is evidently going into receiver standards. While receivers are not the only reason for ETSI’s RED revisions, they are presumably a significant part of the 169 separately-numbered Harmonised Standards in the pipeline. Of these, 98 Standards have already been cited in the OJEU as of 12 April 2017, and 26 have been published by ETSI and awaiting citation in the OJEU.<br /><br />These requirements obviously do not apply to the US market, but it will be interesting to see if they are observed de facto, given that manufacturers of global products will have to comply with ETSI standards.<br /><div><br /></div>https://deepfreeze9.blogspot.com/2017/05/note-on-receivers-in-eu-radio-equipment.htmlnoreply@blogger.com (Pierre de Vries)0tag:blogger.com,1999:blog-5688599.post-7162695161897272463Fri, 14 Apr 2017 10:37:00 +00002017-08-01T13:15:28.593-07:00ethicsresearchsciencescientific-methodTraditional ethics and standards of scholarshipThe astrophysicist <a href="https://en.wikipedia.org/wiki/Simon_White" target="_blank">Simon White</a> concluded his introduction (<a href="http://wwwmpa.mpa-garching.mpg.de/~swhite/talk/Ringberg16.pdf" target="_blank">pdf</a>) to the 2016 Ringberg workshop on galaxy formation by asking how one developed consensus about what is well established. (Thanks to <a href="https://www.inets.rwth-aachen.de/pma.html" target="_blank">Petri Mähönen</a> for bringing it to my attention.)<br /><br />White’s answer: “Re-emphasise traditional ethics and standards of scholarship.”<br /><br /><a name='more'></a><br />The five specific instructions he supplied apply to any field of inquiry, not just galaxy formation. Here they are, slightly edited (as indicated by square brackets) to remove the references to astrophysics:<br /><blockquote class="tr_bq">De-emphasise marketing – the goal is not to sell our model to observers, funding agencies or employers, but to understand [the phenomenon being studied]</blockquote><blockquote class="tr_bq">Be up-front, even-handed and explicit about limitations, assumptions and failures, in addition to exhibiting successes</blockquote><blockquote class="tr_bq">Read and discuss related published work in detail – establish, as far as possible, the reasons why it agrees or disagrees with our results</blockquote><blockquote class="tr_bq">Be sufficiently detailed and explicit about what was done in each paper that it is possible for others to understand if they agree or not</blockquote><blockquote class="tr_bq">Do not stop after exhibiting agreement with (some) [evidence] – does this reflects calibration/tuning or an underlying [reality]?</blockquote><br />These principles are clearly the fruit of many years’ experience, and careful thought. They could be applied to planning research, writing a paper, reviewing a paper, or seeking funding. The qualifier that these are <u>traditional</u> ethics and standards implies that White thinks they are no longer being observed in scholarship; cf. Phil Mirowski’s <a href="http://www.hup.harvard.edu/catalog.php?isbn=9780674046467" target="_blank">Science-Mart</a>. O tempora! O mores!<br /><br />I was reminded of DARPA’s “<a href="http://www.darpa.mil/work-with-us/heilmeier-catechism" target="_blank">Heilmeier Catechism</a>” and Dijkstra's <a href="https://www.cs.utexas.edu/users/EWD/transcriptions/EWD09xx/EWD956.html" target="_blank">"Address to my students" number EWD956</a> (I learned about both from Petri, too). Heilmeier how one decides what to do; Dijkstra is how one should do it; and White is how one describes what was done.<br /><div><br /></div>https://deepfreeze9.blogspot.com/2017/04/ethics-and-standards-of-scholarship.htmlnoreply@blogger.com (Pierre de Vries)0tag:blogger.com,1999:blog-5688599.post-8440737328737714390Thu, 09 Mar 2017 17:02:00 +00002017-08-01T13:15:49.632-07:00culturepolicypoliticsregulationTemplates and narratives for changeAt the end of a conversation with <a href="https://en.wikipedia.org/wiki/David_Runciman" target="_blank">David Runcima</a>n about powerful women on the <i><a href="https://www.acast.com/talkingpolitics/talking-politics" target="_blank">Talking Politics</a></i> podcast (<a href="https://www.lrb.co.uk/2017/02/28/talking-politics/talking-politics-mary-beard" target="_blank">reposted on the LRB podcast</a>; their chat starts around 18:00), <a href="https://en.wikipedia.org/wiki/Mary_Beard_(classicist)" target="_blank">Mary Beard</a> had this to say:<br /><blockquote class="tr_bq">The idea that women have a model for doing [changing the structures within which women can think of themselves as ambitious, as powerful, as clever, as articulate, and able to make that kind of difference in the world] -- and I don't mean a kind of role model, but I just mean a kind of cultural template for doing that -- <span style="background-color: #fff2cc;">until we can provide a <i>narrative </i>and a template, then I think we've got a problem</span>.</blockquote>This resonates with what I try (and fail) to do in policy innovation. It's not sufficient to have a new idea (= template). You also need to have a story (= narrative) that explains why anyone should care, and why it makes sense.https://deepfreeze9.blogspot.com/2017/03/templates-and-narratives-for-change.htmlnoreply@blogger.com (Pierre de Vries)0tag:blogger.com,1999:blog-5688599.post-383267080240658213Fri, 10 Feb 2017 21:04:00 +00002017-08-01T13:16:04.195-07:00metaphorspectrumSpectrum is not a scarce natural resource<br />Almost every policy or technology story about radios starts with the litany that Spectrum is a Scarce Natural Resource. I will argue that this claim is false, and that it matters.<br /><br />In short:<br /><ul><li>Spectrum is no more a scarce natural resource than sound.</li><li>It is more accurate and productive to talk about radio operation.</li><li>Rather than saying “spectrum is scarce”, it’s better to say “radio coexistence is hard.”</li></ul>The pay-off is that this alternative language makes us focus on what matters – the best way to arrange the operation of radios – rather than on ways to manage a resource (spectrum) that may or may exist.<br /><br /><a name='more'></a><br /><b>Introduction</b><br /><br />The notion that spectrum is a scarce natural resource is widespread. Here are a couple of recent ones.<br /><br /><blockquote class="tr_bq">The following <a href="https://nsf.gov/news/news_summ.jsp?cntn_id=189863&amp;org=NSF&amp;from=news" target="_blank">was attributed</a>&nbsp;to Jim Kurose, head of NSF’s engineering directorate: "The radio frequency spectrum is a finite but exceedingly valuable natural resource that facilitates a variety of applications and services"</blockquote><blockquote class="tr_bq">A <a href="https://www.bna.com/senate-house-aides-n57982083183/" target="_blank">Bloomberg BNA story</a> about Hill staffers vying to head up the NTIA said that it “plays a critical role in managing one of the country’s most valuable, if intangible, natural resources: radio wave spectrum.”</blockquote><br />The word “spectrum” has a wide range of meanings, and a lot hinges on which one is being used. I’ll work through a list of possible definitions; in summary, there’s no definition for which all three attributes hold.<br /><br />Spectrum could mean<br /><br /><ol><li>A range of radio frequencies</li><li>Radio signals</li><li>Signals in a region of frequency, space and time&nbsp;</li><li>Uses in a frequency, space, time region</li><li>Operating rights in a frequency/ space region</li></ol><br /><br /><b>1. If “spectrum” means a range of radio frequencies…</b><br /><br />People often think of “the radio spectrum” as the frequencies of wireless signals, measured in oscillations per second, called hertz in SI units and abbreviated Hz. This matches the <a href="http://www.its.bldrdoc.gov/fs-1037/dir-013/_1941.htm" target="_blank">definition</a>&nbsp;provided by the US federal government’s Glossary of Telecommunication Terms: “electromagnetic spectrum: The range of frequencies of electromagnetic radiation from zero to infinity.”<br /><br />Spectrum defined as a range of radio frequencies is thus a bounded numerical range; but those numbers are no more a scarce resource than any other physical unit like seconds, meters or kilograms.<br /><br />Therefore, let’s assume next that we’re talking about radio signals, not radio frequencies.<br /><br /><b>2. If “spectrum” means radio signals…</b><br /><br />OK, so let’s define spectrum as the phenomenon that the units refer to: electromagnetic radiation or, more specifically, radio signals (radiation between 3 kHz and 3,000 GHz, to use a typical definition). Electromagnetic radiation is a physical phenomenon and so is “natural” in some sense.<br /><br />However, there is no real limit to the amount of electromagnetic signals (short of frying the fabric of the universe), so one cannot say that spectrum in this definition is scarce. Some of these signals can be put to some use (we use the sun’s light to see by), but calling all radio signals a resource stretches credulity.<br /><br />To underline the point, consider another very similar form of wave radiation: audible sound. Audible frequencies have a finite range (about 20 Hz to 20 kHz) but it’s unlikely anyone would say that sound is scarce, or a resource in the economic sense. Similarly, radio frequencies have some conventional fixed range, but radio signals as such aren’t an economic resource.<br /><br />The reader might object that we’re never concerned with all the radiation in the entire the universe; we’re talking about radiation in a certain frequency band, at a given time and place. Let’s try that next.<br /><br /><b>3. If “spectrum” means radio signals with a given range of frequencies at a particular place and time…</b><br /><br />Adding boundaries in frequency, space and time means we’re talking about radiation in some container. But just as in the previous case, there’s no real limit to the amount of radiation one can have in a container.<br /><br />Someone might object that all those signals will interfere with each other. In fact, they won’t: just like water waves on a pond move through each other without affecting each other, electromagnetic signals propagate through one another without any mutual interaction.<br /><br />Interference can happen, though, in a receiver. This broadens the discussion from radiation and associated transmitters to include receivers, that is devices that convert information carried by electromagnetic radiation to some usable form.<br /><br />Invoking interference suggests considering spectrum to refer to the uses of radio signals.<br /><br /><b>4. If “spectrum” means the uses of radio signals in a particular frequency/space/time region…</b><br /><br />Since humans can’t decode radio signals, the definition of spectrum as uses of radio entails technology. The term “natural” is therefore inapplicable if one uses this definition.<br /><br />So is spectrum, in this definition, scarce? &nbsp;“Spectrum is scarce” can here most generously be taken to mean “the number of concurrent radio uses in given frequency band, time and place is limited.”<br /><br />This statement is true; for any given level of technology and amount of available money, there is a limit on the number of concurrent uses. However, as technology improves, the number of concurrent uses in a given place, time period and frequency range keeps growing. For example, if each transmitter only emits a narrow beam in the direction of its intended receiver, one can have many more concurrent transmissions than if all the transmitters emitted energy in all directions. For a given technology level, one can also increase the number of concurrent uses by investing in more and better equipment. For example, one can increase the number of concurrent Wi-Fi sessions in sports arenas by replacing access points with large numbers of intensively managed, professional grade routers.<br /><br />This means that while spectrum-as-uses is not natural, it may be considered scarce. What about the claim that spectrum-as-uses is a resource? Since dictionaries of economics have very little to say about the concept, so we have to fall back on <a href="https://en.wikipedia.org/wiki/Resource" target="_blank">Wikipedia</a>:<br /><br /><blockquote class="tr_bq">“A resource is a source or supply from which benefit is produced. Typically resources are materials, energy, services, staff, knowledge, or other assets that are transformed to produce benefit and in the process may be consumed or made unavailable.”&nbsp;</blockquote><br />Based on this description, what qualifies “spectrum” as a resource is most likely that an asset is made unavailable in the process of its “use.” It seems pretty clear that radio frequencies or radio signals aren’t resources, but that uses of radio frequencies and (especially) permissions to engage in uses are resources.<br /><br />For spectrum-as-uses, one might say that a resource is in play because one use can block another. That seems to imply scarcity – but it’s not scarcity of uses, but a limitation on the number of concurrent uses. That, finally, takes us to the legal tools used to manage concurrent uses: permissions to operate.<br /><br /><b>5. If “spectrum” means the rights to operate radios a particular frequency/space/time region…</b><br /><br />We’ve arrived at something which is a resource, and is scarce (at least sometimes): radio operating rights. One might think of radio licenses as akin to taxi medallions, i.e. a permit issued by the government that is required to drive a cab in most cities in America. Just like <a href="https://priceonomics.com/post/47636506327/the-tyranny-of-the-taxi-medallions" target="_blank">taxi medallions</a>, radio licenses are scarce, which makes them valuable. Unlike taxi medallions, some – but definitely not all – radio licenses offer exclusive use in a particular frequency band in a specific region.<br /><br />Radio licenses give operators protection against interference from some other operators. A license, and operating permissions generally including unlicensed allocations, entail a long list of parameters that specify service rules: frequency, geography, transmit power mask, allowed uses, single or paired bands, etc. One might thus say that “spectrum” means the collection of such service rules for a given allocation, or for all allocations taken together.<br /><br />The clearest case is an exclusive license to operate a specific service in a specific frequency range in a specific region, such as the licenses that cellular companies buy for huge sums at auction. These licenses are localized monopolies that are necessary to operate a radio business, and thus qualify as a scarce resource. However, since they’re a legal construct, they don’t qualify as a natural resource.<br /><br />So-called unlicensed operation is murkier: anyone with equipment that meets the relevant service rules is allowed to operate. There’s no scarcity in these operating authorizations since there’s no limit on the number of manufacturers that can obtain equipment authorization, or the number of devices they can sell. Since unlicensed devices have to accept interference (https://www.law.cornell.edu/cfr/text/47/15.5) from any other device, they also do not have much in the way of rights, at least in terms of Part 15 rules.<br /><br />To sum up: I’ve shown that there isn’t any definition of “spectrum” for which it is a scarce and natural and a resource. The word has many meanings that vary with context, ranging from frequency ranges to electromagnetic radiation to uses to operating authorizations. At best, radio operating rights are a scarce (though non-natural) resource, at least in the case of licensed services.<br /><br />In short, it’s the object of radio regulation; just as art is whatever artists do, spectrum is whatever spectrum regulators regulate.<br /><br /><b>What about congestion?</b><br /><br />I don’t think congestion is a particularly useful concept in radio management. If we imagine spectrum as frequencies or signals (definitions 1, 2 and 3), there is no limit on the amount of “spectrum.” Spectrum isn’t like a road, where there’s a limit to the number of vehicles that can be carried; the amount of electromagnetic radiation that can be present in a box is unbounded. If use imagines that spectrum is operating permissions (the least inaccurate interpretation, in my mind), it’s hard for me to even being imagining what congestion would mean: operating permissions are immaterial concepts.<br /><br />Of course, few people would find the claim “spectrum is congested” to be surprising. What they mean, I think, is that the amount of concurrent usable operation in a box is limited, and as the number of concurrent uses goes up, performance goes down – which is analogized to “congestion”. (In other words, they’re using definition 4.) As I noted above, the problem isn’t the signals – &nbsp;which don’t affect each other – but the receivers. Again, I end up at the conclusion that we should be talking about radios, not spectrum.<br /><br />So after all that, I’m left with two questions: Why is this meme so strong? And why does it matter?<br /><br /><b>Why this "spectrum is a resource" language?</b><br /><br />The pervasive invocation of spectrum a scarce natural resource legitimizes government regulation of radio operation. Scarce resources connote the need for management, and invoking the halo word “natural” justifies government ownership by analogy to natural resources like water, oil and minerals where the government’s right to manage the resource is unquestioned.<br /><br />For example, here’s the ITU in a tutorial about Spectrum Management Fundamentals: “The radio frequency spectrum … is a very precious resource which must be managed to ensure efficient and equitable access for the services which use it.”<br /><br />The tenor of official statements is that (with apologies to <a href="https://en.wikipedia.org/wiki/Love_and_Marriage" target="_blank">Frank Sinatra and Sammy Cahn</a>) regulation and resource go together like a horse and carriage: you can’t have one without the other.<br /><br />The need for regulatory legitimacy, combined with famous charts that lay out radio services like plots of land along a frequency axis, leads easily to talking about spectrum as a scarce natural resource.<br /><br />However, I don’t believe one needs the “scarce natural resource” rhetoric to justify radio regulation. The alternative formulation I will propose not only does that, but also avoids some unfortunate side effects of spectrum-as-resource language.<br /><br />A more productive (and accurate) alternative to spectrum as a scarce natural resource: radio operation<br /><br />Avoiding spectrum/resource language doesn’t mean that the government doesn’t have the responsibility or right to regulate. The analogy with audible sound is pertinent: we don’t have property rights in sound, but there are noise ordinances. Noise codes regulate sound sources, for example by setting different limits for exterior sound levels in residential, commercial, and industrial districts, and specifying quiet hours and hours during which construction and maintenance are allowed. No “sound is a thing” assumption is required to get regulatory traction.<br /><br />Conceiving of spectrum as a resource leads to futile polemics about whether “spectrum” should be treated – and more importantly, assigned for use – as private property or as a commons. As regulatory practice has shown, it’s not an either/or choice: the spectrum regulators around the world have used both property-like licenses and commons-like rules, and both have brought great benefit.<br /><br />The assumption that spectrum is a thing can lead to the wrong things being regulated. “Spectrum” is at best a conventional term, used unthinkingly without considering its intended meaning; it’s often just a buzzword that’s used to check a box; at worst it smuggles in unjustified conclusions.<br /><br />A fixation on spectrum, whether as frequency ranges, electromagnetic radiation or permissions to transmit signals, leads to a fixation on transmitters, following the reasoning that since spectrum is signals, the things that create signals (i.e. transmitters) are the object of regulation. However, as has become increasingly well accepted in recent years, receivers play just as important a role as transmitters in deriving maximum possible value from radio operation.<br /><br />On the other hand, <a href="http://deepfreeze9.blogspot.com/2009/09/no-more-s-word.html" target="_blank">I’ve shown</a> that it’s possible to avoid the term “spectrum” completely. One can talk about what matters – the operation of radios – rather than about something (“spectrum”) that doesn’t have a stable or accepted definition.<br /><br />This is easy to do: For example, just say “overlapping use is hard”, or “licenses are in great demand”, rather than saying “spectrum is scarce.” (By “use” I mean the use of radios, not the use of “spectrum”. “Overlapping” refers to concurrent productive use of multiple radio systems in the same frequency, time and place.)<br /><br />A few more translations:<br /><br /><blockquote class="tr_bq">SAY “radio regulation”<br />&nbsp; &nbsp;RATHER THAN “spectrum regulation”<br />SAY “operating radios”<br />&nbsp; &nbsp;RATHER THAN “using spectrum”<br />SAY “overlapping uses”<br />&nbsp; RATHER THAN “a chunk of spectrum”<br />SAY “co-operating radios”<br />&nbsp; &nbsp;RATHER THAN “spectrum sharing”<br />SAY “operating permissions are a resource”<br />&nbsp; RATHER THAN “spectrum is a resource.”</blockquote><br />The pay-off is that this language makes us focus on what matters – the best way to arrange the operation of radios – not on ways to manage a resource (spectrum) that may or may exist.<br /><br />It may also need to new ways to manage radios by making it easier to discard conceptual boxes like frequency bands and license areas, leading to more fluid and flexible radio system operations.<br /><br />In truth I don’t have a good answer for the pay-off question yet. I know that talking about radios rather than spectrum is closer to reality, and that’s likely to yield benefits. It’s like moving from Ptolemy’s description of astronomical bodies moving on epicycles around the earth to Copernicus’s heliocentric model. The Copernican model wasn’t any better as a description than the Ptolemaic one: because it assumed circular orbits, it still had to invoke epicycles, and in fact made worse predictions. However, it opened the path to Kepler’s elliptical orbits (which did provide more accurate predictions than Ptolemy) and ultimately to Newtonian dynamics.<br /><br /><i>Thanks to Dale Hatfield and Blake Reid for their ideas and pointers.&nbsp;</i>https://deepfreeze9.blogspot.com/2017/02/spectrum-is-not-scarce-natural-resource.htmlnoreply@blogger.com (Pierre de Vries)0tag:blogger.com,1999:blog-5688599.post-7847682410877257693Sun, 08 Jan 2017 19:50:00 +00002017-01-09T10:48:32.841-08:00revolutionspectrumtrendsYou say you want a spectrum revolutionI’ll be attending the <a href="https://www.ptc.org/ptc17" target="_blank">PTC’17</a> conference in a couple of weeks. Our panel is tackling the question <a href="https://www.ptc.org/ptc17/program-and-attendees/complete-program/details.html?sid=362" target="_blank">The Spectrum Revolution: Where, What, Why, How?</a>, which got me thinking… <br /><a name='more'></a><br /><br /><b>You say you want a revolution...</b> (<a href="http://www.azlyrics.com/lyrics/beatles/revolution.html" target="_blank">lyrics</a>)<br /><br />Revolutions are dreadful things. They typically kill thousands of people (sometimes millions), and leave societies crippled for decades: France, Russia, Mexico, China, Iran, etc. And those are the few that "succeed". Most revolts end in a bloody return to the status quo: Spartacus, Wat Tyler, 1848, the Arab Spring, etc.<br /><br />Techno-economic revolutions aren't as lethal, but not much better for those left behind; just ask the voters in Michigan how they feel about automation and globalization. Do we really want a spectrum revolution?<br /><br />It’s curious, at first glance, that a conference where <a href="https://www.ptc.org/ptc17" target="_blank">more than 70%</a> of the attendees are service providers or carriers is so interested in revolution. Incumbents hate radical change, i.e. revolutions, so why do they want to hear about it? Daniel Gilbert gives some answers in his 2007 best-seller, <a href="https://www.amazon.com/Stumbling-Happiness-Daniel-Gilbert/dp/1400077427" target="_blank">Stumbling on Happiness</a> (pp. 20-21). According to him, there two reasons we worry about the future even though it makes us feel bad. First, anticipating unpleasant events can minimize their impact on us when they do occur; second, worry and anxiety can motivate us to do the right thing by dramatizing the unpleasant consequences of not doing so. There’s also a related reason mentioned in a lovely recent <a href="http://www.footnotinghistory.com/home/ghosts-of-christmas-past" target="_blank">podcast</a> about Victorian ghost stories: we might fear that progress is taking us somewhere we don’t want to go.<br /><br /><b>What would it take to trigger a revolution?</b><br /><br />What might count as a spectrum revolution, i.e. change that unseats the companies and industries currently in the driver's seat? Here are some possibilities:<br /><br /><ul><li>Spectrum allocations are abolished, leaving radios to figure out among themselves how to operate without causing interference. This dream was the subtext of the <a href="https://www.whitehouse.gov/sites/default/files/microsites/ostp/pcast_spectrum_report_final_july_20_2012.pdf" target="_blank">PCAST spectrum report</a>. For contrasting academic approaches, see <a href="https://www.aeaweb.org/articles?id=10.1257/jep.22.1.103" target="_blank">Hazlett</a> and <a href="http://www.benkler.org/agoraphobia.pdf" target="_blank">Benkler</a>.&nbsp;</li></ul><br /><ul><li>Federal spectrum allocations are abolished; federal users have to buy operating rights on the open spectrum market. For one approach, see Tom Lenard's ideas about "<a href="https://techpolicyinstitute.org/press_release/establish-gsa-for-government-spectrum/" target="_blank">GSA for Government Spectrum</a>."</li></ul><br /><ul><li>Above some frequency (30 GHz, for argument sake) indoor spectrum rights are controlled by property owners, not the FCC. Since wall attenuation is so high, there's no risk of interference with public/outdoor deployments where the regulator would retain control.&nbsp;</li></ul><br /><ul><li>All (new?) spectrum allocations are for flexible, auctioned, exclusive use; no more commons.</li></ul><br /><ul><li>All (new?) spectrum allocations are for unlicensed, commons use; no more auctions and exclusive licenses.</li></ul><br /><ul><li>The FCC is abolished - not only the legacy telecom/internet and broadcasting/media stuff, but spectrum management as well.</li></ul><br />I don't think any of them are in the cards, though. For example,<br /><br /><ul><li>I struggle to see how a world without allocations would work, either technically or politically, even if one focused just on domestic operations and ignored treaty obligations on (say) satellite services. There’s been a lot of talk about cognitive radio and Dynamic Spectrum Allocation over the last 15 years – the current buzzword is Spectrum Access Systems – but regulatory action has been meagre and the implementations so far are rudimentary. The legal questions are harder than the engineering ones: how would one define rights clearly enough that diverse parties (and not just repeat players in the same game, like cellular companies sorting out inter-system interference) could figure out disputes without endless litigation?</li></ul><br /><ul><li>Assigning indoor rights to property owners is technically entirely feasible, and is the case de facto in private settings for GHz radios. However, the legal and financial status quo (e.g. regulators jealously guarding their prerogatives, and the value of spectrum licenses on cellco balance sheets, respectively) is very strong.</li></ul><br /><ul><li>Arguing for radio assignments to be either all-commons or all-licensed is a tired polemic from the early 2000s; both approaches work, and neither is going away.</li></ul><br /><ul><li>Perhaps we magically return to the pre-FCC spectrum situation (priority-in-use rules under common law) before the Red Lion decision and the 1927 Radio Act instituted a regime of public interest regulation by a commission. (For this history, see Hazlett's <a href="https://ssrn.com/abstract=286932" target="_blank">Wireless Craze</a>.) However, in spite of calls to abolish the FCC mostly from right-wing commentators (e.g. <a href="https://www.washingtonpost.com/news/the-switch/wp/2016/11/22/we-dont-need-the-fcc-a-trump-advisers-proposal-to-dissolve-americas-telecom-watchdog/" target="_blank">Marc Jamison</a>) and even <a href="http://www.newsweek.com/lessig-its-time-demolish-fcc-83409" target="_blank">Larry Lessig</a>, spectrum is usually fenced off as an area where a regulator is still required; Marc Jamison noted that “The only FCC activity that would seem to warrant having an independent agency is the licensing of radio spectrum.”</li></ul><br /><b>Revolutionary technology?</b><br /><br />Given our fondness of talking about industrial "revolutions," one might wonder if there are breakthrough technologies on offer - like, for example, the combination of movable type and cheap paper that led to "Gutenberg's revolution"<br /><br />I don't see any; moving to higher frequencies doesn’t change the game. Even impossible stuff like the affordable phased array antennas that are needed for mm-wave cellular handsets won't change anything fundamental; it'll just be more of the same old stuff, at a higher frequency.<br /><br />The closest I can come to potential breakthroughs are:<br /><br /><ul><li>full-duplex transmission actually works (but that would at best double spectral efficiency)</li></ul><br /><ul><li>very high density, accurate RF sensor networks (that could lead to closed-loop control of distributed RF networks) are cheap enough to deploy ubiquitously</li></ul><br /><b>Disruptions</b><br /><br />Since I don't see any impending spectrum revolution, let’s see if there were any disruptions on the horizon. Some possibilities:<br /><br /><ul><li>The MNO business model may be crumbling. &nbsp;ARPU is flat or down, WACC is going to grow (cf. <a href="https://twitter.com/trengriffin/status/279494043707269120" target="_blank">Tren Griffin</a>). The economics of the cellular business (hardware and services, both) are dodgy: revenues are flat or falling, and low cost competitors have entered at least the equipment market. The 5G hype sounds like whistling past the graveyard. Perhaps the king has feet of clay. Mr Schumpeter's ghost is walking.</li></ul><br /><ul><li>Spectrum is moving from ~2D to <a href="http://deepfreeze9.blogspot.com/2016/09/3d-spectrum-management.html" target="_blank">~3D</a>. This creates some new tussles, e.g. cellular is now battling not just the broadcasters but also satellite. The new crop of NGSO players may give GSO satellite companies (and maybe cellular?) a run for their money, though it may be cooperation rather than competition, e.g. Intelsat partnering with OneWeb.</li></ul><br /><ul><li>There's an emerging consensus that the RF noise floor is rising, and that it's no longer only a problem in the low-frequency band nobody cares about. Cellular companies in the UHF are beginning to talk about it. The FCC TAC had a technical enquiry this past year, and recommended FCC lab testing and NOI/NPRMs. It's not going to change industry structure, though.</li></ul><br /><ul><li>The FCC enforcement function's been cut severely, and there's no prospect of recovery. That may prompt more delegated/distributed enforcement. I've called for parties to interference disputes to have a right of private action before ALJs, and federal/commercial sharing may have to fall back on contracts not rules. We may also see more "posse enforcement", i.e. private parties taking on regulator-like roles, e.g. in SAS bands. (We have a precedent in frequency coordinators.) I can't see this changing industry structure, but power relationships could be tweaked.</li></ul><br />None of these seem particularly earth-shaking, though.<br /><br /><b>Lessons from history?</b><br /><br />I started wondering about what a disruption (or even revolution) might look like, so I started thinking about historical precedents. One can multiply examples indefinitely; here are a few examples of technologies that did (or didn't) restructure industries:<br /><br /><ul><li>Radio broadcast: AM - yes; FM - no; DAB, SDARS - no.</li><li>Video broadcast: TV - yes; DBS - no in US, yes in UK.</li><li>moving to new frequency bands: shortwave to medium wave - no; medium wave to VHF - maybe; VHF to UHF - no.</li><li>satellite: GSO - yes; NGSO - no.</li><li>spectrum policy: spread spectrum unlicensed - yes; auctions - no.</li><li>cellular: introduction - yes; GSM - maybe; CDMA - no; iPhone - yes; Android - no.</li></ul><br />There are also all the promised disruptions that never happened. The list is endless, but here are a few radio ones I can think of: Northpoint, M2Z, UWB, digital radio (DAB), unlicensed PCS, LightSquared.<br /><br />The moral of these stories is that disruption is possible – AM, TV, spread spectrum unlicensed, cellular, iPhone – but that it’s rare.<br /><br /><b>Caveat</b><br /><br />I am neither distinguished nor (quite yet) elderly, but Clarke’s First Law should be quoted at this point:<br /><br /><blockquote class="tr_bq">“When a distinguished but elderly scientist states that something is possible, he is almost certainly right. When he states that something is impossible, he is very probably wrong.”</blockquote><b><br /></b><b>You tell me that it's evolution..</b><br /><br />Overall, then, I’m skeptical about the prospect of earth-shattering changes. There are some incremental but significant things that could shift the ground a little, though:<br /><br /><ul><li>Using risk assessment rather than worst case when deciding allocations (see my <a href="http://ssrn.com/abstract=2792395" target="_blank">paper</a>)</li></ul><br /><ul><li>Decentralized dynamic access, along the lines of DARPA's <a href="http://spectrumcollaborationchallenge.com/" target="_blank">SC2</a></li></ul><br /><ul><li>RF mirror worlds: closed-loop measurement/simulation/control systems that run spectrum models in parallel with real-world deployments (see my <a href="http://deepfreeze9.blogspot.com/2014/03/rf-mirror-worlds.html" target="_blank">blog</a>)</li></ul><br />The wireless business seems pretty resilient to disruption, however, leaving me wondering what one would have to do to actually GET a disruption, let alone a revolution. A tech breakthrough is necessary, but given regulatory sclerosis, political and business change may also be necessary... A collapse of the cellular business model would help shake things up, particularly if it coincided with eight years of deregulatory fervor.<br /><br />https://deepfreeze9.blogspot.com/2017/01/spectrum-revolution.htmlnoreply@blogger.com (Pierre de Vries)0tag:blogger.com,1999:blog-5688599.post-8147182043662469586Sun, 25 Sep 2016 19:59:00 +00002017-07-01T02:03:32.373-07:00aviationdronesregulationspectrum3D Wireless: Managing spectrum in three dimensionsIt is time to manage spectrum in three dimensions, rather than on a slightly wrinkled 2D sheet.<br /><br /><a name='more'></a>Traditional spectrum policy is mostly a two-dimensional problem. It talks about license areas (not volumes) and protection contours (not bubbles). The key determinant in managing interference between radios is the horizontal distance between them.<br /><br />It’s not quite flatland, of course. Many signal propagation models (key to interference analysis) include the heights of transmitters and receivers as well as intervening obstacles, but typically horizontal distances are much, much larger than vertical ones. Satellite systems are an exception, but even here one could call it essentially 2 ½ dimensional: satellites up high, strung out like pearls along a geostationary orbit, beaming down 2D patches of coverage onto the earth. &nbsp;And the propagation is essentially a line: geostationary satellites are roughly 1,000 times as high as continents are wide.<br /><br />This two dimensionality started breaking down with the dense urban deployment of cellular systems. The vertical position of handsets in tall building relative to base stations started to matter, not only in positioning and pointing antenna systems appropriately but even in the requirements for locating emergency calls: the FCC’s E911 requirement now calls for vertical location information for calls originating in multi-story buildings.<br /><br />New plans for constellations of low earth orbiting satellites (the last generation mostly failed: remember Teledesic?), high altitude broadband platforms like Facebook’s Aquila and Google’s Loon, and the prospect of the mass deployment of drones and clouds of cubesats are leading to spectrum management becoming a 3D world. Radios will not just be on the earth’s surface and in geostationary orbit (and a few airplanes), but at a whole range of altitudes between zero and 36,000 km.<br /><br />We need to start thinking seriously about a 3D Wireless World. If that’s is the vision, the three major tasks are:<br /><ul><li>Build: the design and engineering challenge of creating the devices and systems to realize the vision; and the policy challenge of creating a new regulatory framework, encompassing aeronautical, aviation and communications agencies</li></ul><ul><li>Manage: the measurements, operations, and government regulations to ensure the effective and beneficial operation of the components and systems</li></ul><ul><li>Use: all the applications that use the 3D wireless infrastructure, from earth science and weather forecasting to navigation to delivering broadband services in new ways, to name a few.</li></ul><br />The FCC has thought about 3D spectrum management in a piecemeal way over the years<br /><ul><li>Coexistence between “horizontal” and “vertical” services, e.g. Northpoint’s (failed) broadband distribution service in the satellite TV broadcast band; unlicensed Wi-Fi networks and Globalstar satellite uplinks in the 5 GHz band; and cellular point-to-point links and satellite earth stations in the millimeter wave bands</li></ul><ul><li>Allowing terrestrial operation in bands planned for satellite services, e.g. adding terrestrial transmitters for audio broadcast (SiriusXM) or cellular service (LightSquared)</li></ul><ul><li>And most recently, work at the ITU on command-and-control links for drones</li></ul><br />The time has come to think holistically about the 3D Wireless World we’re busily building.<br /><div><br /></div>https://deepfreeze9.blogspot.com/2016/09/3d-spectrum-management_25.htmlnoreply@blogger.com (Pierre de Vries)0tag:blogger.com,1999:blog-5688599.post-4860409577809299194Thu, 28 Jul 2016 17:12:00 +00002017-08-01T13:17:53.553-07:00lawmetaphorFitting square pegs into bicyclesTo this non-lawyer, jurisprudence often seems to be metaphor mongering/mangling/wrangling -- as in Judge Easterbrook's contention that that there was no more a “law of cyberspace” than there was a “Law of the Horse" ("<a href="http://www.law.upenn.edu/fac/pwagner/law619/f2001/week15/easterbrook.pdf" target="_blank">Cyberspace and the Law of the Horse</a>" (1996); see also Larry Lessig's "<a href="https://cyber.law.harvard.edu/works/lessig/finalhls.pdf" target="_blank">The Law of the Horse: What Cyberlaw Might Teach</a>").<br /><br />From a recent CS Monitor comes the latest in this inexhaustible genre: "<a href="http://www.csmonitor.com/Business/new-economy/2016/0726/Is-bitcoin-money-Are-Airbnbs-hotels-Why-courts-have-trouble-deciding" target="_blank">Is bitcoin money? Are Airbnbs hotels? Why courts have trouble deciding</a>."<br /><br /><a name='more'></a><br />A couple of excerpts:<br /><blockquote class="tr_bq">A Florida circuit-court judge’s Monday ruling that bitcoin is not money is the latest addition to a confusing jumble of definitions and regulations that have attempted to classify and control digital currency. . . . Since Florida doesn’t have a law specific to digital, or virtual, currency, applying laws that regulate money-service businesses to bitcoin transactions “is like fitting a square peg in a round hole," Pooler wrote.</blockquote><blockquote class="tr_bq">...&nbsp;</blockquote><blockquote class="tr_bq">... jamming pegs into ill-suited holes is just what some law enforcement, tax and other regulators across the globe are trying to do as they struggle to apply traditional laws to technology innovations that defy them.</blockquote><br />David Bach and Jonathan Sallet wrote a fascinating article about this a decade ago in FirstMonday: "<a href="http://firstmonday.org/htbin/cgiwrap/bin/ojs/index.php/fm/article/view/1255/1175" target="_blank">The challenges of classification</a>" (2005).<br /><br />Perhaps Sallet will revisit this topic when he leaves the FCC. Do we need a new way to extend the applicability of law, given the breakneck introduction of new concepts? &nbsp;For example, perhaps one should focus on use of the technology, not the technology as such. Privacy is trying this, as the community experiments with moving from notice &amp; consent to use &amp; disclosure. Here's another excerpt from the CS Monitor story, quoting Marco A. Santori, a partner specializing digital currency at a NYC law firm:<br /><br /><blockquote class="tr_bq">"Bitcoin is not a currency, it’s not a commodity, it’s a computer protocol. . . . the computer protocol is being used as money, it should be regulated as money. If it is being used a security, it should be regulated as security. If it is being used a commodity or derivative or a dessert topping, it should be regulated as such."</blockquote><div><br /></div>https://deepfreeze9.blogspot.com/2016/07/fitting-square-pegs-into-bicycles.htmlnoreply@blogger.com (Pierre de Vries)0tag:blogger.com,1999:blog-5688599.post-3840712474899159909Fri, 15 Apr 2016 19:07:00 +00002017-08-01T13:20:25.795-07:00hypnosismeditationplaceboHypnosis, placebo and meditationIn its recent package on The Power of Mind (<a href="https://www.newscientist.com/issue/3064/" target="_blank">issue no 3064</a>, 12 March 2016), New Scientist includes an <a href="https://www.newscientist.com/article/2079647-i-can-tell-you-how-to-heal-yourself-with-hypnosis/" target="_blank">interview</a> with <a href="https://www.psychologytoday.com/experts/laurence-irwin-sugarman-md" target="_blank">Laurence Sugarman</a> at Rochester, who uses hypnosis in clinical settings -- and believes that mindfulness meditation is an example of hypnosis.<br /><br /><a name='more'></a><br />Sugarman says, “My colleagues and I propose that hypnosis is simply a skill set for influencing people. It involves facial expression, language, body movement, tone of voice, intensity, metaphor, understanding how people interpret and represent things.”<br /><br />He observes that hypnosis is a medium for delivering placebo effects, and defines placebo as “the use of conditioning, expectation, social relationships and narrative paradigm to change a person’s physiology in a way that they attribute to an external intervention."<br /><br />Sugarman's claim that mindfulness meditation is an example of hypnosis reminded me of a story SN Goenka tells about a doctor giving a prescription for medicine to a sick man during the <a href="http://www.vridhamma.org/The-Discourse-Summaries#Three" target="_blank">Day Three discourse</a> of the 10 day vipassana course. It’s used to explain three kinds of wisdom:<br /><blockquote class="tr_bq">"The man goes home, and out of great faith in his doctor, he recites the prescription every day; this is <i>suta-maya pann</i>a [wisdom acquired by hearing or reading the words of another]. Not satisfied with that, the man returns to the doctor, and demands and receives an explanation of the prescription, why it is necessary and how it will work; this is <i>cinta-maya panna</i> [intellectual understanding]. Finally the man takes the medicine; only then is his disease eradicated. The benefit comes only from the third step, the <i>bhavana-maya pann</i>a [the wisdom that develops within oneself, at the experiential level]."</blockquote>Mr Goenka takes a hard line: only the medicine itself has any effect. Neither having faith in the doctor and the treatment, nor understanding rationally how the medicine works, has any benefit.<br /><br />The emerging consensus on placebo seems to contradict this, at least as far as medical treatment goes. It suggests that the benefit does not only come from the story's third step, the actual taking of the medicine. Having faith in the doctor, and understanding how the medicine works, also helps.<br /><br />For example, here are some excerpts from the article “<a href="https://www.newscientist.com/article/2079643-tap-the-placebo-effect-to-unlock-your-bodys-healing-powers/" target="_blank">Tap the placebo effect to unlock your body's healing powers</a>” in the same New Scientist package:<br /><blockquote class="tr_bq">"We now know that when a person is given a pill they’re told is a real medication, or any of a wide range of medical interventions, including surgery, their body creates a real physiological effect. In pain studies, placebos have been shown to dampen activity in the brain’s pain-processing areas and increase the production of the body’s own analgesic chemicals."</blockquote><blockquote class="tr_bq">“One key to unlocking the body’s self-healing mechanisms seems to be the setting up of an expectation of improvement. And it works the other way too: if you think your drug has been replaced with a placebo, even a strong painkiller’s effects will be dulled.”</blockquote><blockquote class="tr_bq">On why the “honest placebo”, i.e. telling patients ahead of time that their pills contain no medication, actually works: “One theory concerns the expectations set by the intervention itself. “It’s not just the drug, it’s everything that surrounds the drug,” says Kaptchuk [a placebo researcher]. Placebos are not inert substances: they are made of verbal suggestion, classical conditioning, and a lifetime’s associations learned about the cues of the medical ritual: the white coat, the office, the doctor’s manner. Any and all of these may cue the body’s healing powers.”</blockquote><br />This suggests that faith in the effectiveness of a meditation technique, whether it’s blind faith or based on reason, is likely to strengthen the beneficial effects. Faith is obviously helps in remaining dedicated and motivated; however, it may go deeper than that. It also implies that rituals, which are often decried (not least by Mr Goenka himself), have value that goes far beyond their superficial appearance.<br /><div><br /></div>https://deepfreeze9.blogspot.com/2016/04/hypnosis-placebo-and-meditation.htmlnoreply@blogger.com (Pierre de Vries)1tag:blogger.com,1999:blog-5688599.post-1986663115588349431Mon, 31 Aug 2015 20:44:00 +00002017-08-01T13:20:55.618-07:00astronomyinterferencerisk-assessmentworst-caseFCC approves robotic lawn mower, rejects worst case analysisOn August 12, 2015 the FCC granted a waiver (<a href="http://transition.fcc.gov/Daily_Releases/Daily_Business/2015/db0812/DA-15-915A1.pdf" target="_blank">pdf</a>) of some Part 15 rules to allow iRobot to market a robotic lawn mower transmitting in the 6240-6740 MHz range (Order in Proceeding <a href="http://apps.fcc.gov/ecfs/proceeding/view/view?name=15-30" target="_blank">15-30</a>). The National Radio Astronomy Observatory (NRAO) had expressed concern that the waiver could lead to interference to radio astronomy operations.<br /><br /><a name='more'></a><br />The Office of Engineering and Technology noted in its waiver grant that "because the NRAO analysis looked at line-of-sight separation distances, it has greatly overestimated the interference potential of transmitters that are located less than two feet above the ground."<br /><br />It added, "We find that when taking into account the variability in propagation characteristics due to terrain, low antenna heights and other propagation factors, grant of this waiver is very unlikely to increase the potential for harmful interference."<br /><br />The glass-half-full reading is that the FCC rejected a worst-case analysis; the glass-half-empty view is that it missed an opportunity to do a probabilistic risk analysis that quantified expressions like "greatly overestimated the interference potential" and "very unlikely to increase the potential for harmful interference."<br /><br />The cynic's take is that this is to be expected; providing hard numbers would expose the Commission to having its reasoning questioned during subsequent litigation.https://deepfreeze9.blogspot.com/2015/08/fcc-approves-robotic-lawn-mower-rejects.htmlnoreply@blogger.com (Pierre de Vries)0tag:blogger.com,1999:blog-5688599.post-1027803317271529208Mon, 31 Aug 2015 19:24:00 +00002017-08-01T13:21:23.569-07:00interferencerisk-assessmentworst-caseWorst case in interference analysis for medical interferenceIn its&nbsp;second order on reconsideration regarding the incentive auction released on June 19, 2015 (docket 12-268, <a href="https://apps.fcc.gov/edocs_public/attachmatch/FCC-15-69A1.pdf" target="_blank">pdf</a>) the FCC noted that its analysis interference into wireless medical telemetry systems its work "is a worst case analysis and in most installations one or more of the parameters we assumed here will provide additional protection" (recon order at para 119).<br /><br /><a name='more'></a><br />Even this wasn't good enough for GE Healthcare, who filed a <a href="http://apps.fcc.gov/ecfs/document/view?id=60001118878" target="_blank">petition</a> on July 28, 2015 asking the FCC to reconsider its reconsideration, saying&nbsp;"Due to the severe and wide-ranging negative consequences of interference to Channel 37 WMTS, the Commission's expressed intent to use a worst-case (i.e. minimum coupling loss) analysis in evaluating separation between Channel 37 WMTS and 600 MHz band mobile base stations is appropriate, but its adopted separation rules are not, in fact, based on a worst-case analysis, as the Commission appears to believe."<br /><br />The trouble with worst case is that there is no worst case. That is: one can always imagine something worse. It’s not a sufficiently stable concept to be usable. This leads to oxymorons like the “realistic worst-case” GE HealthCare refers to in its petition. It leads to oxymorons like the “realistic worst-case” GE HealthCare refers to.<br /><br />There’s even a term of art: RWCS, the Reasonable Worst Case Scenario, that even has a definition in the UK: a scenario "designed to exclude theoretically possible scenarios which have so little probability of occurring that planning for them would be likely to lead to disproportionate use of resources” (House of Commons Select Committee <a href="http://www.publications.parliament.uk/pa/cm201011/cmselect/cmsctech/498/49807.htm" target="_blank">Report</a>). (There's also the term "reasonably foreseeable worst case use scenarios" that's used in passing in IEC 60601.)<br /><div><br /></div>It’s related to the unbounded character of the maximum of a distribution. &nbsp;It’s well known among statisticians, but apparently not that many spectrum folk, that the longer you sample&nbsp;a parameter with an unbounded distribution (e.g. a propagation path loss with a log-normal fading distribution), the larger the&nbsp;maximum you find will be.https://deepfreeze9.blogspot.com/2015/08/worst-case-in-interference-analysis-for.htmlnoreply@blogger.com (Pierre de Vries)0tag:blogger.com,1999:blog-5688599.post-135679966304672277Fri, 31 Jul 2015 20:49:00 +00002015-07-31T13:58:05.800-07:00adjudicationharm-claim-thresholdspolicyrisk-assessmentspectrumQ&A: Risk-assessment, harm claim thresholds and adjudicationIn my testimony before the Senate Commerce Committee on Wednesday July 29, 2015 I recommended three spectrum management reforms. A summary and links to the written testimony and video are in <a href="http://deepfreeze9.blogspot.com/2015/07/senate-testimony-risk-assessment-harm.html" target="_blank">an earlier blog post</a>. This post offers some Q&amp;A.<br /><br />The three reforms were: (1) moving away from worst case interference analysis and using risk-informed methods that consider not only the consequences but also the likelihood of harmful interference; (2) providing more clarity about operators’ interference rights and obligations by specifying harm claim thresholds; and (3) giving any spectrum user the option of taking action directly against any other, either in front of an FCC judge or in a federal Court of Spectrum Claims.<br /><a name='more'></a><br /><br /><b>1.1<span class="Apple-tab-span" style="white-space: pre;"> </span>When you talk about decentralization or shifting management to the marketplace, do you mean deregulation?</b><br /><br />No.<br /><br />Implementing the tools I recommend does not mean that the FCC would give up authority. &nbsp;It would be using its authority in different ways, such as using alternatives to command and control as a way to achieve its policy goals.<br /><br />Doing this would simply recognize an inevitable consequence of our increasingly varied, crowded and dynamic spectrum reality: the need for private parties to take more responsibility for some aspects of routine spectrum management, notably adjusting rights boundaries and rights enforcement.<br /><br />As a formal legal matter (caveat: IANAL) the FCC would still have the authority to change its mind, e.g. to roll back regulatory changes.<br /><br />The goal is to enable private ordering and remove the FCC from a gatekeeping role where appropriate, e.g. in routine spectrum management. &nbsp;The spectrum geek’s shorthand is "Coasian spectrum policy reform."<br /><br /><b>1.2<span class="Apple-tab-span" style="white-space: pre;"> </span>How would your three initiatives appeal to the deregulatory-minded since they all seem to require regulatory actions or institutions?&nbsp;</b><br /><br />All three facilitate a more economically informed view and allow more private ordering:<br /><ul><li>Risk-informed interference assessment lends itself to being used in combination with cost/benefit analysis since it takes a quantitative, full-system view of interactions between incumbents and newcomers.</li></ul><ul><li>Harm claim thresholds provide a solid basis for parties to negotiate adjustments to the FCC’s initial definition of rights; they are a basis for what’s called “interference trading”.</li></ul><ul><li>Private adjudication lets parties take action against someone they believe is harming their operation, without having to wait for the FCC to get around to it—or ties resolution of the dispute to some other, unrelated matter that is also before the Commission.</li></ul><br /><b>1.3<span class="Apple-tab-span" style="white-space: pre;"> </span>On the other hand, how do they appeal to those who don't think of centralization as a problem?</b><br /><br />None of the proposals the FCC's authority:<br /><ul><li>Risk-informed interference assessment is just another (though I think better) tool to use in deciding allocations.</li></ul><ul><li>Harm claim thresholds retain and build on the definition of harmful interference in 47 CFR Part 2.1 by adding a quantitative test before a party can claim harmful interference—which would still be adjudicated using the definition in Part 2.1.</li></ul><ul><li>Private adjudication gives parties an alternative way to resolve interference problems. If the FCC is functioning well, it won’t be used.</li></ul><br />Many who see an important role for government worry about the abuse of market power. All three proposals will probably tend to reduce the uphill slope of the playing field that faces new entrants.<br /><br /><b>1.4<span class="Apple-tab-span" style="white-space: pre;"> </span>What about sharing v. clearing, or licensed v. unlicensed?</b><br /><br />The challenges we face apply regardless of whether one favors<br /><ul><li>spectrum sharing, clearing and reallocation, or some hybrid (like the AWS-3 blocks where cellular licensees have to protect weather satellite earth stations); or</li></ul><ul><li>licensed or unlicensed allocation, or some hybrid (such as the 3.5 GHz band where unlicensed devices will be controlled by a Spectrum Access System).&nbsp;</li></ul>These choices are important, but the answer won’t fundamentally change the underlying physics and governance challenges that come with squeezing more, and more diverse, services ever more closely together.<br /><br />The remedies I propose apply regardless of these choices.<br /><br /><b>1.5<span class="Apple-tab-span" style="white-space: pre;"> </span>What is risk assessment?</b><br /><br />Risk assessment sets out to answer three questions: What can go wrong? How likely is it? What are the consequences?<br /><br />For example, when considering whether to install a burglar alarm system one might consider the various circumstances under which unwanted people might enter your house; how likely each possibility might be; and what might harm might befall in each case, from pranks and petty larceny to assault.<br /><br /><b>1.6<span class="Apple-tab-span" style="white-space: pre;"> </span>What’s the difference between worst case and a risk-informed assessment?</b><br /><br />In engineering practice, risk is typically evaluated by considering the combination of likelihood and consequence for multiple hazards. By contrast, a worst case analysis focuses on a single scenario with very severe consequences, regardless of its likelihood.<br /><br />For example, when deciding on the amount of domestic protection to buy, most consumers do not plan for a worst case like home invasion. Rather, they take a view—based on the likely threats in their neighborhood, the severity of outcomes, their personal need for security, and costs—of various options like deadbolts, burglar bars, intrusion alarms and steel doors.<br /><br /><b>1.7<span class="Apple-tab-span" style="white-space: pre;"> </span>What are the benefits of risk-informed interference assessment?</b><br /><br />Quantitative risk assessment will improve the analysis of harmful interference, and lead to wiser trade-offs.<br /><br />The benefits include:<br /><ul><li>Providing quantitative information to policy decision-makers who are balancing the benefits of a new service against its adverse technical impact on incumbents;</li></ul><ul><li>Providing a single framework for comparing different interference scenarios and assessments, in other words, enabling apples-to-apples comparisons of different kinds of interference; and</li></ul><ul><li>Enhancing the completeness of analysis and increasing the chances of identifying unexpected harmful interference mechanisms.</li></ul><br /><b>1.8<span class="Apple-tab-span" style="white-space: pre;"> </span>How can Congress encourage the FCC and NTIA to start using quantitative risk assessment?</b><br /><br />Options for Congressional action include: <br /><ul><li>Making it part of the oversight process</li></ul><ul><li>By requiring risk assessment in legislation</li></ul><ul><li>By making sure that the FCC and NTIA—through auction revenues or otherwise—have the resources to advance the state of the art in spectrum management.&nbsp;</li></ul><ul><li>By encouraging research on this specific topic by federal labs, NSF etc.</li></ul>(On legislation: Various executive orders (Clinton 1993, Bush 2003, Obama 2011) have required risk analysis and cost/benefit analysis – but Executive Order 12866 and circular A-4 don’t apply to independent agencies. The CRS (2014) believes the the President could amend Executive Order 12866 and OMB circular A-4, or Congress could enact legislation.)<br /><br /><b>1.9<span class="Apple-tab-span" style="white-space: pre;"> </span>Why does one need to adjust the rules after they’re made?</b><br /><br />The rules that govern how radios are operated aim to strike a balance between the interests of incumbents and the value of new services. Given the imperfect information available to the regulators, the balance is probably not optimal, and even if it was perfect to begin with, it will become obsolete as technologies, businesses and missions evolve. Adjustments to the rules are therefore inevitable and desirable.<br /><br /><b>1.10<span class="Apple-tab-span" style="white-space: pre;"> </span>What problem does harm claim thresholds solve?</b><br /><br />The FCC does not generally define rights and obligations clearly, providing clarification only after lengthy rulemaking—and such clarifications are purposely ad hoc and cannot be generalized. <br /><br />In the past, with fewer demands on the resource, the FCC could afford to proceed in this manner. Going forward, this model of spectrum management will become more and more costly to adhere to.<br /><br />At the moment, adjusting the rules almost always has to be done by the regulators, which is slow and inefficient. We need to delegate as much spectrum management as possible from regulators to spectrum users.<br /><br /><b>1.11<span class="Apple-tab-span" style="white-space: pre;"> </span>What are the benefits of harm claim thresholds?</b><br /><br />Setting a harm claim threshold will help parties to optimize spectrum boundaries and resolve disputes among themselves, without relying on the government.<br /><ul><li>It reduces uncertainty about the rights and responsibilities regarding interference for both interfering and affected parties, allowing them to plan and invest with more confidence.</li></ul><ul><li>It moves decisions about system design, including receiver performance, away from government to where it belongs: with manufacturers and operators.</li></ul><ul><li>It allows parties themselves to adjust operating rights and spectrum boundaries, which reduces rent seeking and the load on regulators.</li></ul><ul><li>It facilitates the resulting negotiations by providing an unequivocal starting point.</li></ul><b>1.12<span class="Apple-tab-span" style="white-space: pre;"> </span>Why is federal spectrum, in particular, a problem for enforcement and adjudication?</b><br /><br />The challenge is particularly acute when it comes to federal spectrum uses, since these services are vital to that national interest, they are growing for the same reasons as private uses and, in many cases, federal jurisdiction over spectrum bands is shared with the FCC.<br /><br /><b>1.13<span class="Apple-tab-span" style="white-space: pre;"> </span>Are you saying that all three initiatives must be adopted together as a package? If you could only recommend one, which would it be? Why?</b><br /><br />The three each bring benefits on their own, but there are synergies as I described in my remarks.<br /><br />If I had to choose one (and I'd rather not) it would be risk-informed assessment.<br /><ul><li>It’s the biggest bang for the buck, since it can affect all new allocations</li></ul><ul><li>There is a recognition at the FCC that there needs to be more use of statistical analysis, i.e. looking at the probabilities of various events, not just the worst case.</li></ul><br />Harm claim thresholds are a close second, since the method is already in use, both by private parties (AT&amp;T and Sirius XM) and by the FCC (3.5 GHz rules for Priority Access License systems).<br /><br />https://deepfreeze9.blogspot.com/2015/07/q-risk-assessment-harm-claim-thresholds.htmlnoreply@blogger.com (Pierre de Vries)0tag:blogger.com,1999:blog-5688599.post-2287949849617374481Wed, 29 Jul 2015 18:40:00 +00002015-07-31T16:11:41.528-07:00adjudicationharm-claim-thresholdspolicyrisk-assessmentspectrumSenate Testimony: Risk-assessment, harm claim thresholds and adjudicationI testified today before the Senate Commerce Committee hearing on “<a href="http://www.commerce.senate.gov/public/index.cfm?p=Hearings&amp;ContentRecord_id=57a2f3e1-d86f-4f1a-bb33-36502d4002ce&amp;ContentType_id=14f995b9-dfa5-407a-9d35-56cc7152a7ed&amp;Group_id=b06c39af-e033-4cba-9221-de668ca1978a" target="_blank">Wireless Broadband and the Future of Spectrum Policy</a>.” My written testimony is <a href="http://www.commerce.senate.gov/public/index.cfm?p=Hearings&amp;ContentRecord_id=57a2f3e1-d86f-4f1a-bb33-36502d4002ce&amp;Statement_id=0a66ea5e-d7ef-44de-b0c7-a7718b6be732&amp;ContentType_id=14f995b9-dfa5-407a-9d35-56cc7152a7ed&amp;Group_id=b06c39af-e033-4cba-9221-de668ca1978a&amp;MonthDisplay=7&amp;YearDisplay=2015" target="_blank">here</a>; this is the summary I presented during the hearing. I’ve posted some Q&amp;A in <a href="http://deepfreeze9.blogspot.com/2015/07/q-risk-assessment-harm-claim-thresholds.html" target="_blank">a subsequent post</a>.&nbsp;My remarks are recorded in the archived webcast, starting at <a href="http://www.senate.gov/isvp/?type=live&amp;comm=commerce&amp;filename=commerce072915&amp;stt=00:58:02&amp;auto_play=true" target="_blank">58:02</a>; see also a question from Chairman Thune and my reply starting at <a href="http://www.senate.gov/isvp/?type=live&amp;comm=commerce&amp;filename=commerce072915&amp;stt=02:05:43&amp;auto_play=true" target="_blank">2:05:43</a>.<br /><a name='more'></a><br />There is no need to rehearse the boom in wireless services and technologies, and the incredible opportunities of using spectrum. I have come to believe that the promised spectrum bonanza will much reduced if government doesn’t create tools to respond to the unprecedented diversity and crowding in spectrum.<br /><br />The more we squeeze services together in frequency, space and time, the greater the cost of unwise spectrum allocation, and the greater the risk of service failures due to harmful interference. The problem is not unlike that of a booming city that must make room for more and more traffic of all shapes and sizes—pedestrians, bicycles, motorbikes, cars, trucks, buses, etc.—at the same time that real estate values are exploding and space is at a premium.<br /><br />The growing variety, intensity and dynamism of spectrum use requires that regulators make initial rules wisely, and that we find ways to shift routine spectrum management—like rule adjustments and dispute resolution—from regulators to users.<br /><br />My written testimony details three important steps that I’m convinced will help deliver on the promise of spectrum. Each addresses a different stages of the spectrum life-cycle:<br /><br />1.<span class="Apple-tab-span" style="white-space: pre;"> </span><i>When planning new allocations</i>, the FCC and NTIA should move away from worst case interference analysis and <b>use risk-informed methods</b> that consider not only the consequences but also the likelihood of harmful interference.<br /><br />2.<span class="Apple-tab-span" style="white-space: pre;"> </span><i>When issuing operating rights</i>, regulators should be clearer about operators’ interference rights and obligations by <b>specifying harm claim thresholds</b>. The FCC typically doesn’t define rights and obligation very clearly; the ambiguity helps to prevent any possible interference. This made sense when spectrum rights were not in such great demand. It is not tenable given the crowded spectrum bazaar we now face. Harm claim thresholds are good fences, and they will make for good neighbors.<br /><br />3.<span class="Apple-tab-span" style="white-space: pre;"> </span><i>When in the middle of interference disputes</i>, any spectrum user should have the option of <b>taking action directly against any other</b>, either in front of an FCC judge or in a federal Court of Spectrum Claims. A federal court is essential because there is currently no venue where intractable disputes between the FCC and NTIA can be resolved. Fact-based, transparent, and timely adjudication will facilitate better spectrum management.<br /><br />While I am convinced that each of these recommendations on its own will bring great benefits, there are significant synergies between them.<br /><br />1.<span class="Apple-tab-span" style="white-space: pre;"> </span>Bargaining and contracting based on harm claim thresholds is facilitated by a well-functioning system of dispute resolution.<br /><br />2.<span class="Apple-tab-span" style="white-space: pre;"> </span>In turn, adjudication is facilitated by clear statements of the rights and obligations to interference protection as enshrined in harm claim thresholds.<br /><br />3.<span class="Apple-tab-span" style="white-space: pre;"> </span>And finally, risk-informed rather than worst-case interference assessment makes for wise rights allocation and efficient enforcement with a quantitative way to balance the interests of interfering and interfered-with services.<br /><br />Congress plays a vital role. Here are three things it can do:<br /><br />1.<span class="Apple-tab-span" style="white-space: pre;"> </span>Take a risk-informed view yourselves, when presented with questions of harmful interference, and avoid (the temptation of) fixating on the worst case;<br /><br />2.<span class="Apple-tab-span" style="white-space: pre;"> </span>Encourage the FCC and NTIA to use risk-informed interference assessment, and to be more explicit about interference rights and obligations; and<br /><br />3.<span class="Apple-tab-span" style="white-space: pre;"> </span>Create a Court of Spectrum Claims within the US Court of Federal Claims.<br /><br /><br />https://deepfreeze9.blogspot.com/2015/07/senate-testimony-risk-assessment-harm.htmlnoreply@blogger.com (Pierre de Vries)0tag:blogger.com,1999:blog-5688599.post-1851431846741516508Sun, 14 Jun 2015 01:44:00 +00002017-06-04T12:22:10.798-07:00allocationfccharm-claim-thresholdsreceiversrisk-assessmentrulemakingPrinciples for interference assessment and receiver protection in FCC rulemakingsA key consideration in spectrum policy, particularly the allocation of new services, is the protection of existing services against harmful interference. However, regulators take an ad hoc approach to defining harmful interference. We would be better served if everyone knew, up-front, the principles a regulator was going to use when making decisions about a new allocation.<br /><br />Julie Knapp’s comment at a recent FCC TAC meeting have inspired me to sketch out some principles/guidelines/framework for the FCC when looking at protecting services during rulemakings. Julie pointed out that the TAC Spectrum and Receivers Working Group now has an opportunity to synthesize and make actionable our work of the last few years.<br /><br />(Update: The FCC TAC adopted "Basic Principles for Assessing Compatibility of New Spectrum Allocations" [<a href="https://www.fcc.gov/bureaus/oet/tac/tacdocs/meeting121015/Principles-White-Paper-Release-1.1.pdf" target="_blank">pdf</a>] at its meeting on December 9, 2015. I participated in drafting this document, and I'm delighted that it aligns well with the principles I outlined here.)<br /><a name='more'></a><b><br /></b><b>Harmful Interference</b><br /><br />Harmful interference arises due to the interaction of two services. It is a function of the characteristics of both the interfering service and the affected service. The characteristics of the affected system, notably its receiver characteristics but also other attributes like transmitter power and location topology, can contribute to harmful interference. Therefore, <b>both the interfering and affected systems share the responsibility to avoid harmful interference</b>. To date, however, regulation has focused on the transmissions of the interfering service and ignored the ability of the affected service to reject interference.<br /><br />Affected non-safety services are protected against “[i]nterference which … seriously degrades, obstructs, or repeatedly interrupts” their operation (47 CFR 2.1 definition). They are not protected against any interference whatever, just interference that rises to this level. <b>Services should therefore expect and plan for non-harmful interference to their service from current or future adjacent allocations</b>. Affected services should bear in mind that the general definition of interference includes “any performance degradation, misinterpretation, or loss of information which could be extracted in the absence of such unwanted energy”; they should therefore expect and plan for performance degradation, misinterpretation, or loss of information which does not rise to the level of serious degradation, obstruction, or repeated interruption of their service.<br /><br />To fairly partition the operation of interfering transmitters and affected receivers, <b>interference assessments should by default be done at the receiving antenna input</b>, not at or beyond the receiver input. This default may be over-ridden where entrenched custom or international norms require, such as in protecting high gain satellite earth station receivers.<br /><br /><b>Protection of Reception</b><br /><br />Since receiver characteristics are one determinant of whether a service experiences harmful interference, <b>the Commission should expect that a service’s receivers, and operations generally including transmitter power and deployment, meet industry standards or guidelines</b>. It should base its assessment of the probability and impact (i.e. the risk) of harmful interference on this expectation. Where industry standards or guidelines do not exist, the Commission should base its assessment on the performance of the majority of receivers in the affected service, not the poorest-performing one. (One could be more prescriptive here, e.g. specifying that the FCC should not protect receivers falling, say, more than one standard deviation below the mean on key receiver characteristics, listed below.)<br /><br />Operators in the affected service are expected to <b>disclose the relevant standards, guidelines or operating (e.g. receiver) characteristics if they require protection</b>. Neither the Commission nor an interfering service can protect what it does not know about. Where receiver and system operating characteristics are disclosed, they should include at least the following (cf. “Table 20. Example of a Generic Receiver Spectrum Standard” in <a href="http://www.its.bldrdoc.gov/publications/2435.aspx" target="_blank">NTIA Report 03-404</a>)<br /><br /><ul><li>Receiver characteristics such as spurious response rejection, adjacent channel rejection, semi-adjacent channel rejection, 60 dB selectivity, intermodulation rejection, image frequency rejection, blocking immunity, and minimum and maximum sensitivity (i.e. dynamic range)</li></ul><ul><li>System characteristics such as SINR and margin minima, transmitter deployment, antenna characteristics, and operating bandwidth.</li></ul><br />As a guide to the approach the Commission may take in its analysis, one could start with the following general principles and adjust them to reflect the specifics of a particular case:<br /><br /><ul><li>An existing service should not expect protection from interference, such as limits on an interferer’s transmit power or resulting interfering field strength, at more than a reasonable frequency offset from the boundaries of the service’s assignment; the boundary in question may be a channel or a band edge, depending on the case. As a rule of thumb, a service should not expect out-of-assignment protection at more than (say) three times the bandwidth of its assignment from the edges of its allocated band (cf. the NTIA Report’s “60 dB Selectivity” requirement).</li></ul><ul><li>Unless the contrary is shown to be required, the Commission should assume that a receiver’s selectivity follows the same (inverted) roll-off pattern as the transmit mask of its desired transmission. (Obvious exceptions include TV transmit and receive masks; the obvious test case is GPS, but radar probably also falls in this category.)</li></ul><br />The performance of a receiving system is important in ensuring that harmful interference does not occur. While the Commission is unlikely to specify receiver performance characteristics, it can use <b>interference limits policies</b>, i.e. ways to describe the environment in which a receiver must operate without necessarily specifying receiver performance. For example, it may specify <b>harm claim thresholds</b>, i.e. in-band and out-of-band interfering signal levels that must be exceeded before a system can claim that it is experiencing harmful interference; see FCC TAC (2014) "<a href="http://transition.fcc.gov/oet/tac/tacdocs/reports/TACInterferenceLimitsIntrov1.0.pdf" target="_blank">Interference Limits Policy and Harm Claim Thresholds: An Introduction</a>". Ideally, system characteristics and harm claim thresholds will be agreed by contending parties using multi-stakeholder processes; the Commission could establish default thresholds that stakeholders are free to change and improve by mutual agreement.<br /><br />To facilitate affected services in bringing enforcement actions against interferers, the Commission may designate <b>conformance to a specific receiver performance standard as a safe harbor</b> for asserting that a harm claim threshold has been exceeded; that is, if a receiver meeting such a standard suffers severe performance degradation, the harm claim threshold will be deemed to have been exceeded without measurements or modeling being required to validate the claim.<br /><br /><b>Worst case and risk assessment</b><br /><br />RF signals, both wanted and unwanted, fluctuate everywhere and all the time due to the physics of electromagnetic propagation. Further, the protection criteria of repeated interruption and serious degradation imply extended and widespread service loss; occasional degradation and interruption at various places and times is unavoidable and does not rise to the level of harmful interference. <b>Protection against harmful interference is therefore a statistical matter.</b> Rules can at most protect services against harmful interference in most places, most of the time; guaranteed, universal protection is unattainable and should not be expected.<br /><br />Specifically, the Commission should not make allocation decisions on the basis of worst case failure scenarios. It should make risk-informed interference assessments that take into account both the consequence and likelihood of interference hazards; see e.g. FCC TAC (2015) "<a href="http://transition.fcc.gov/bureaus/oet/tac/tacdocs/meeting4115/Intro-to-RIA-v100.pdf" target="_blank">A Quick Introduction to Risk-Informed Interference Assessment</a>." (Of course, in the final analysis the Commission is required to act in the public interest, which includes but goes beyond technical considerations.) <b>It should not protect against the worst case</b>, but similarly it should not afford protection only against harmful interference hazards based on average values of interference parameters; the offered protection will be somewhere between these two extremes.<br /><br />Parties petitioning the Commission regarding harmful interference are encouraged to provide quantitative risk assessments. If a party bases its arguments on a single harm scenario, e.g. a worst case, it should provide evidence not just for its impact but also estimate the likelihood of the hazard.<br /><br /><b>Taking a broad perspective</b><br /><br />Wireless systems are vulnerable to many failure modes beyond those attributable to interference from other services. &nbsp;Examples include RF noise from unintentional radiators, incorrect configuration, power failure, excessive link range, self-interference, etc. &nbsp;Interference from other services can be a low probability cause of failure compared to these baseline hazards. The Commission should <b>assess the relative risk of harm due to a new allocation by comparing it to a baseline</b>, i.e. the incidence and severity of pre-existing causes of service degradation, and may require those seeking protection to submit data on baseline outages.<br /><br />The Commission should take a holistic view of protection against harmful interference: <b>affected systems should be expected to use interference mitigation methods not only at the radio layer</b> in the specific assignment in question, but to use a variety of techniques (where available) including antenna patterns that apply nulls to sources of interference, using alternative radio channels, mitigation higher up in the communication stack such as error correction protocols at the link layer, and repositioning receivers and interfering transmitters both in space and frequency The mere fact that a particular channel may be unavailable due to interference need not amount to service interruption or degradation to the extent of harmful interference if alternatives and/or mitigations are available.<br /><br /><b>Caveats/context/disclaimers</b><br /><br />While this came up in the context of the receiver characteristics, and reception is a key part of the new thinking, it’s about more than just receivers; rather, it’s about expectations of protection against harmful interference more generally, and so also encompasses interference limits policy and risk assessment.<br /><br />I’m focusing for now on adjacent channel/band allocation, not co-channel sharing.<br /><br />I haven’t tried to connect it with enforcement.<br /><br />I’m focusing for now on non-safety services, leaving aside for later refinement the inclusion of “radionavigation service or [of] other safety services” that are entitled to protection against their “functioning” being “endanger[ed]” (47 CFR 2.1 definition of harmful interference)<br /><br /><br /><br /><br /><br /><br /><br /><br /><br /><br /><br /><br />https://deepfreeze9.blogspot.com/2015/06/principles-for-interference-assessment.htmlnoreply@blogger.com (Pierre de Vries)0tag:blogger.com,1999:blog-5688599.post-7571500041789234656Thu, 12 Feb 2015 18:42:00 +00002015-04-27T13:09:21.458-07:00policyregulationrisk-assessmentspectrumRisk-informed interference assessmentI've spent the last year or so thinking about ways to complement worst-case interference assessment with a more comprehensive approach that considers many potential interference hazards, not just a possibly implausible nightmare scenario. I have concluded that quantitative risk analysis, used in many regulated industries, is a suitable tool.<br /><br /><a name='more'></a><br />In judging whether to allow new service rules, a regulator has to balance the interests of incumbents, new entrants and the public. The trade-off between the benefits of a new service and the risks to incumbents has to date been essentially qualitative. This short paper proposes the use of quantitative risk analysis to assess the harm that may be caused by changes in radio service rules.<br /><br />Risk analysis considers the likelihood-consequence combinations for multiple hazard scenarios, and complements a “worst case” analysis that considers the single scenario with the most severe consequence, regardless of its likelihood. Risk-informed interference assessment is the systematic, quantitative analysis of interference hazards caused by the interaction between radio systems. Such an assessment has three major steps:<br /><br />1.<span class="Apple-tab-span" style="white-space: pre;"> </span>Make an inventory of all significant harmful interference hazard modes.<br />2.<span class="Apple-tab-span" style="white-space: pre;"> </span>Define a consequence metric to characterize the severity of hazards.<br />3.<span class="Apple-tab-span" style="white-space: pre;"> </span>Assess the likelihood and consequence of each hazard mode.<br /><br />Quantitative risk assessment can:<br /><br /><ul><li>provide a common currency for comparing different interference scenarios and assessments;</li><li>enhance the completeness of analysis and increase the chances of identifying unexpected harmful interference mechanisms;</li><li>provide objective information to policy decision makers balancing the benefits of a new service and its adverse technical impact on incumbents.</li></ul><br />Implementing quantitative risk assessment requires a change in culture, and will take time. A regulator (like the FCC) should therefore start small, but start soon:<br /><br /><ul><li>Develop know-how in the agency and the wider community, for example through a lecture series on modern risk management, and—if there is an on-going education facility like the FCC University—by offering courses to staff on statistics and risk-management.</li></ul><ul><li>Use quantitative risk assessment in its own work, and publish the analyses and results.</li></ul><ul><li>Provide quantitative guidelines on unquestionably acceptable and unacceptable interference risks, respectively, e.g. as likelihood-consequence regions on a risk chart.</li></ul><ul><li>Pilot this approach in selected site-specific license waiver proceedings.</li></ul><br />For more, please see <a href="http://ssrn.com/abstract=2564213">http://ssrn.com/abstract=2564213</a>.<br /><br /><b>Note</b>: My thinking has developed in the context of the FCC TAC’s interest in the statistics of interference, and specifically the work of the 2014 Spectrum and Receiver Performance working group. Since the TAC process has stalled for organizational reasons, this is my personal take on the subject. I hope a group consensus will emerge soon.<br /><br /><b>Update</b>: The FCC TAC Spectrum and Receiver Performance working group &nbsp;published "A Quick Introduction to Risk-Informed Interference Assessment" early in April 2015:&nbsp;<a href="http://transition.fcc.gov/bureaus/oet/tac/tacdocs/meeting4115/Intro-to-RIA-v100.pdf">http://transition.fcc.gov/bureaus/oet/tac/tacdocs/meeting4115/Intro-to-RIA-v100.pdf</a><br /><div><br /></div><br /><br />https://deepfreeze9.blogspot.com/2015/02/risk-informed-interference-assessment.htmlnoreply@blogger.com (Pierre de Vries)0tag:blogger.com,1999:blog-5688599.post-8193917238591244921Sun, 28 Dec 2014 17:41:00 +00002015-02-12T10:42:45.448-08:00auctionsfccNodeXLspectrumSix weeks of spectrum auction tweetsI created an animated GIF to show how twitter traffic about spectrum auctions changed over the first six weeks of the AWS-3 auction, i.e. November 15 to December 27.<br /><br /><div class="separator" style="clear: both; text-align: center;"><a href="http://3.bp.blogspot.com/-eN5feFGTytk/VKAzAsEdcLI/AAAAAAAAAdA/LBTavlfYoT0/s1600/NodeXLGraph42.4%2BGraphAnimation%2B4241883.gif" imageanchor="1" style="margin-left: 1em; margin-right: 1em;"><img border="0" src="http://3.bp.blogspot.com/-eN5feFGTytk/VKAzAsEdcLI/AAAAAAAAAdA/LBTavlfYoT0/s1600/NodeXLGraph42.4%2BGraphAnimation%2B4241883.gif" height="240" width="320" /></a></div><br /><br /><a name='more'></a><br />The graphs are generated through an analysis in <a href="https://nodexlgraphgallery.org/Pages/AboutNodeXL.aspx" target="_blank">NodeXL</a> of the results of a search for tweets that contained the terms&nbsp;"(spectrum auction) OR (incentive auction) OR (airwave auction)". There were a total of 7,403 tweets by 4,094 users.<br /><br />To drill down on the graph detail for each frame, here are the SNApshots from the NodeXL Graph Gallery, with characteristic word pairs/strings (see "Top Word Pairs" in the SNApshots; my capitalization) in brackets:<br /><br /><a href="https://nodexlgraphgallery.org/Pages/Graph.aspx?graphID=36318" target="_blank">Whole period</a> (34 billion, record bids)<br /><a href="https://nodexlgraphgallery.org/Pages/Graph.aspx?graphID=36319" target="_blank">Week 1</a> (commencing February 23, inter ministerial group forms, 30 billion)<br /><a href="https://nodexlgraphgallery.org/Pages/Graph.aspx?graphID=36320" target="_blank">Week 2</a> (record 34 billion, record bids)<br /><a href="https://nodexlgraphgallery.org/Pages/Graph.aspx?graphID=36322" target="_blank">Week 3</a> (3G February TRAI, defence requirement CDMA)<br /><a href="https://nodexlgraphgallery.org/Pages/Graph.aspx?graphID=36323" target="_blank">Week 4</a> (surpasses 41, FCC AWS3)<br /><div><a href="https://nodexlgraphgallery.org/Pages/Graph.aspx?graphID=36325" target="_blank">Week 5</a> (Canada unveils plan, 44 billion)</div><div><a href="https://nodexlgraphgallery.org/Pages/Graph.aspx?graphID=36327" target="_blank">Week 6</a> (give government unexpected gift 44 billion)</div><div><br /></div>While most of the traffic is evidently about the AWS-3 auction in the U.S., the search has also picked up some other stories, such as the planned February auction of 3G spectrum in India.<br /><br />As time passes one can see various users come and go as they tweet about this topic. However, a core group keeps chugging through the whole period. (The animation was made by locking the vertices in their positions generated by NodeXL for the full period, and then subsetting vertices that tweeted -- i.e. had edges -- in the successive weeks.)<br /><br />The most connected users over the entire period, measured by <a href="http://en.wikipedia.org/wiki/Betweenness_centrality" target="_blank">betweenness centrality</a>, are a mix of news services (@wsj, @bw, @theeconomist, <a href="https://twitter.com/fiercewireless" target="_blank">@fiercewireless</a>), users in India (@helal_786, @ratanmaitra, @yr_conscience, <a href="https://twitter.com/dramoly" target="_blank">@dramoly</a>) and the usual US spectrum suspects (@fcc, <a href="https://twitter.com/mark_goldberg" target="_blank">@mark_goldberg</a>, <a href="https://twitter.com/tmfassociates" target="_blank">@tmfassociates</a>, @sutherla, <a href="https://twitter.com/waltbtig" target="_blank">@waltbtig</a>).<br /><br />Since betweenness includes nodes that are mentioned by many others but don't tweet often themselves (e.g. @fcc), a "reach" metric such as number of tweets ("out-degree", in the parlance) multiplied by the log of a user's followers ("log" to take into account the diminishing returns of many followers); by this measure, the top ten influencers are:<br /><br />@4gspectrum<br /><a href="https://twitter.com/tmfassociates" target="_blank">@tmfassociates</a><br />@maglancapital<br /><a href="https://twitter.com/waltbtig" target="_blank">@waltbtig</a><br /><a href="https://twitter.com/fiercewireless" target="_blank">@fiercewireless</a><br />@fcc_cio<br /><a href="https://twitter.com/mark_goldberg" target="_blank">@mark_goldberg</a><br />@hbuskirk<br />@ctia<br /><a href="https://twitter.com/dramoly" target="_blank">@dramoly</a><br /><div><br /></div><div>There is a reassuring overlap with the betweenness stars, but spectrum commentators are more heavily represented.</div><div><br /></div><div>Filtering the graph to just show <a href="https://nodexlgraphgallery.org/Pages/Graph.aspx?graphID=36379" target="_blank">users that converse with each other</a> yields a much smaller group: just 64 users. Most of them are in pairwise dialogs, but a few them (including some of the Usual Suspects) chat in small groups. (The thumbnails are scaled to the number of tweets.)</div><div><br /></div><div class="separator" style="clear: both; text-align: center;"><a href="https://nodexlgraphgallery.org/Images/Image.ashx?graphID=36379&amp;type=f" imageanchor="1" style="margin-left: 1em; margin-right: 1em;"><img border="0" height="231" src="https://nodexlgraphgallery.org/Images/Image.ashx?graphID=36379&amp;type=f" width="320" /></a></div><div><br /></div><br /><br />https://deepfreeze9.blogspot.com/2014/12/six-weeks-of-spectrum-auction-tweets.htmlnoreply@blogger.com (Pierre de Vries)0tag:blogger.com,1999:blog-5688599.post-8561036040997443979Sun, 07 Sep 2014 00:03:00 +00002014-09-06T20:04:37.430-07:00net-neutralityNodeXLSNApshotsocialnetworkstwitterBeyond the main stage: Teasing apart twitter traffic about net neutrality<br />For this installment of the NodeXL Gallery Glimpse, I'm teasing apart the members of the social graph around the net neutrality issue.<br /><br /><div class="separator" style="clear: both; text-align: center;"><iframe allowFullScreen='true' webkitallowfullscreen='true' mozallowfullscreen='true' width='320' height='266' src='https://www.youtube.com/embed/BYS8gVQMH7I?feature=player_embedded' FRAMEBORDER='0' /></div><br /><a name='more'></a><br /><br />I began by running a search for all tweets that contained the terms "netneutrality" and "net neutrality" over the three week period from&nbsp;Saturday 23 Aug to Friday 5 Sep 2014, inclusive. That yields this SNApshot,&nbsp;<a href="https://nodexlgraphgallery.org/Pages/Graph.aspx?graphID=27302">https://nodexlgraphgallery.org/Pages/Graph.aspx?graphID=27302</a>:<br /><br /><div class="separator" style="clear: both; text-align: center;"><a href="https://nodexlgraphgallery.org/Images/Image.ashx?graphID=27302&amp;type=f" imageanchor="1" style="margin-left: 1em; margin-right: 1em;"><img border="0" height="287" src="https://nodexlgraphgallery.org/Images/Image.ashx?graphID=27302&amp;type=f" width="400" /></a></div><br />It has the typical structure of a <a href="http://www.pewinternet.org/2014/02/20/part-2-conversational-archetypes-six-conversation-and-group-network-structures-in-twitter/#network-type-4-community-clusters" target="_blank">Community Cluster</a>, as defined in the Pew Research paper "<a href="http://www.pewinternet.org/2014/02/20/mapping-twitter-topic-networks-from-polarized-crowds-to-community-clusters/" target="_blank">Mapping Twitter Topic Networks: From Polarized Crowds to Community Clusters</a>":<br /><ol><li>A large block of <b>disconnected contributors</b> who mention the topic but do not link to one another - the big group in the band across the top</li><li>A number of <b>large hubs</b> around a core user that everyone mentions, with loose connections between the hubs.&nbsp;</li></ol>Each hub is what the Pew authors call a <a href="http://www.pewinternet.org/2014/02/20/part-2-conversational-archetypes-six-conversation-and-group-network-structures-in-twitter/#network-type-5-broadcast-networks" target="_blank">Broadcast Network</a>, in which many people repeat what the prominent node at the center has tweeted, leading to edges pointing in to the core from the surrounding cloud. In this case, the top vertex (by betweenness centrality) is <a href="https://twitter.com/fightfortheftr" target="_blank">@fightfortheftr</a>, and people are retweeting its <a href="https://cms.fightforthefuture.org/tellfcc/" target="_blank">call to sign a petition</a> to the FCC; and not surprisingly, the #2 vertex is <a href="https://twitter.com/fcc" target="_blank">@fcc</a>, mentioned in all the retweets.<br /><br />In community cluster community clusters, not all in-pointing hubs are worshipful; in some cases, they're disparaging. In this case, many edges point to <a href="https://twitter.com/nctacable" target="_blank">@nctacable</a> because users are criticizing an <a href="https://www.ncta.com/platform/public-policy/where-we-stand-on-net-neutrality/" target="_blank">policy statement</a> made by the trade association. Perhaps one should think of them as "attribution networks" rather than broadcast networks. The image I have is of a lot of people shouting at a person up on a pedestal - sometimes cheering, and sometimes booing.<br /><br />In the usual fashion, NodeXL lists the key word pairs for the entire graph which capture the gist of the conversation:<br /><blockquote class="tr_bq"><b>Top Word Pairs in Tweet in Entire Graph</b>:<br />sept,10th<br />10th,internetslowdown<br />happen,lose<br />show,world<br />what'll,happen<br />internetslowdown,show<br />world,what'll<br />dear,everyone<br />everyone,need<br />need,isp</blockquote>This is pretty much the same as the word pairs for the group of disconnected contributors, which isn't surprising since they make up about a third of the vertices in the graph (34.5%, or 2,645 of 7,659 vertices).<br /><br />But what about the connected components?<br /><br />To explore this, I removed the disconnected contributors, to yield the SNApshot&nbsp;<a href="https://nodexlgraphgallery.org/Pages/Graph.aspx?graphID=27303">https://nodexlgraphgallery.org/Pages/Graph.aspx?graphID=27303</a>:<br /><br /><div class="separator" style="clear: both; text-align: center;"><a href="https://nodexlgraphgallery.org/Images/Image.ashx?graphID=27303&amp;type=f" imageanchor="1" style="margin-left: 1em; margin-right: 1em;"><img border="0" height="288" src="https://nodexlgraphgallery.org/Images/Image.ashx?graphID=27303&amp;type=f" width="400" /></a></div><br />It shows the 5,014 users (= 7,659 - 2,645) that mentioned other twitter users in their tweets. The overall message hasn't changed much. The "<a href="https://www.battleforthenet.com/sept10th/" target="_blank">Sept. 10th is the Internet Slowdown</a>" campaign, but the ever-motivating Koch brothers have crept into the Top 10:<br /><blockquote class="tr_bq"><b>Top Word Pairs in Tweet in Entire Graph</b>:<br />dear,everyone<br />everyone,need<br />need,isp<br />isp,leave<br />fightfortheftr,dear<br />leave,htt<br />according,koch<br />sept,10th<br />10th,internetslowdown<br />happen,lose</blockquote>The users that are the centers of attention of the hubs are identical:<br /><blockquote class="tr_bq"><b>Top 10 Vertices, Ranked by Betweenness Centrality:</b><br />fightfortheftr<br />fcc<br />nctacable<br />youranonnews<br />techcrunch<br />washingtonpost<br />motherboard<br />firefox<br />namecheap<br />doctorow</blockquote>But is there actually any interaction around this topic, or are people just sharing loves and hates with their friends, and not actually hearing back from them?<br /><br />To find out, I kept only the vertices that shared reciprocating edges, that is, keep @Alice and @Bob only if @Alice mentioned @Bob in a tweet, and @Bob mentioned @Alice. One wouldn't expect much to remain, since the&nbsp;Reciprocated Edge Ratio listed for the original SNApshot&nbsp;<a href="https://nodexlgraphgallery.org/Pages/Graph.aspx?graphID=27302">https://nodexlgraphgallery.org/Pages/Graph.aspx?graphID=27302</a>was only 2.8%.<br /><br />Indeed we end up with a rather small graph,&nbsp;<a href="https://nodexlgraphgallery.org/Pages/Graph.aspx?graphID=27307">https://nodexlgraphgallery.org/Pages/Graph.aspx?graphID=27307</a>, with only 138 vertices:<br /><br /><div class="separator" style="clear: both; text-align: center;"><a href="https://nodexlgraphgallery.org/Images/Image.ashx?graphID=27307&amp;type=f" imageanchor="1" style="margin-left: 1em; margin-right: 1em;"><img border="0" height="288" src="https://nodexlgraphgallery.org/Images/Image.ashx?graphID=27307&amp;type=f" width="400" /></a></div><br />This is a very different cast of characters: not the Big Names that people are admiring (or hating) from afar, but the people who are talking to each other about net neutrality. Here, then, is one way to find the true grassroots activists:<br /><blockquote class="tr_bq"><b>Top 10 Vertices, Ranked by Betweenness Centrality:</b><br /><a href="https://twitter.com/debttrut" target="_blank">debttrut</a>&nbsp;("Our system, in the last 40 years, has institutionalized a MEME that it's OK TO BE RAVENOUSLY GREEDY ...")<br /><a href="https://twitter.com/ajain31" target="_blank">ajain31</a>&nbsp;("A Liberal Dem #Obama follower &amp; Twitteraholic ...")<br /><a href="https://twitter.com/ammori" target="_blank">ammori</a>&nbsp;("lots of stuff. net neutrality stuff recently")<br /><a href="https://twitter.com/acequiero1" target="_blank">acequiero1</a>&nbsp;("Acequia Farmer and Professor. ... Environmental Justice Activist")<br /><a href="https://twitter.com/latinorebels" target="_blank">latinorebels</a>&nbsp;("Humor, commentary &amp; analysis of US Latin@ world")<br /><a href="https://twitter.com/futuretensenow" target="_blank">futuretensenow </a>("overs emerging technologies and their implications for society and polic")<br /><a href="https://twitter.com/culturejedi" target="_blank">culturejedi </a>("writer, communications organizer, and director at the center for media justice")<br /><a href="https://twitter.com/insidesourcesdc" target="_blank">insidesourcesdc</a>&nbsp;("News. Elevated. Raising the debate to a higher level.")<br /><a href="https://twitter.com/fredbcampbelljr" target="_blank">fcamp</a><a href="https://twitter.com/fredbcampbelljr" target="_blank">redb</a><a href="https://twitter.com/fredbcampbelljr" target="_blank">belljr </a>("Executive Director of the Center for Boundless Innovation in Technology")<br /><a href="https://twitter.com/avilarenata" target="_blank">avilarenata </a>("https://twitter.com/avilarenata")</blockquote>The Top 10 seem to be left-wing activists (surprise!), with one exception: <a href="https://twitter.com/fredbcampbelljr" target="_blank">@fredbcampbelljr</a>. However, a few well-known right wingers also appear, e.g. <a href="https://twitter.com/bskorup" target="_blank">@bskorup</a> and <a href="https://twitter.com/larrydownes" target="_blank">@larrydownes</a> in G10. The Big Fish in the fight, <a href="https://twitter.com/fightfortheftr" target="_blank">@fightfortheftr</a>, does reciprocate, but conversed with <a href="https://twitter.com/popresistance" target="_blank">@popresistance</a>.<br /><br />Drawing big conclusions about such a small network is not wise, however. I'd want to look at more than three weeks of traffic before I was confident about the nature and influence of the grassroots leaders I've identified here. Still, with that caveat: This "only reciprocating" graph helps one delve into texture of a topic, away from the glare and hype of the main stages.<br /><br /><br />https://deepfreeze9.blogspot.com/2014/09/teasing-apart-net-neutrality-twitter.htmlnoreply@blogger.com (Pierre de Vries)0tag:blogger.com,1999:blog-5688599.post-644951925297266777Mon, 01 Sep 2014 00:25:00 +00002014-09-01T09:39:20.386-07:005GNodeXLspectrum5G on Twitter: NodeXL social network analysisA <a href="http://nodexl.codeplex.com/" target="_blank">NodeXL</a> SNApshot is a great way to catch up with who's saying what about a topic on Twitter. This post discusses&nbsp;the SNApshot&nbsp;<a href="http://bit.ly/snapshot-26748">http://bit.ly/snapshot-26748</a> that graphs the 1,963 tweets containing the hashtag #5G posted over the period 17 Jul - 29 Aug 2014.<br /><br />Here's the Gallery Glimpse video:<br /><br /><div class="separator" style="clear: both; text-align: center;"><br /><iframe allowFullScreen='true' webkitallowfullscreen='true' mozallowfullscreen='true' width='320' height='266' src='https://www.youtube.com/embed/IUlPHNXUDFI?feature=player_embedded' FRAMEBORDER='0' /></div><br /><br /><a name='more'></a><br />The video and this blog discusses the page <a href="https://nodexlgraphgallery.org/Pages/Graph.aspx?graphID=26748">https://nodexlgraphgallery.org/Pages/Graph.aspx?graphID=26748</a>:<br /><br /><div class="separator" style="clear: both; text-align: center;"><a href="https://nodexlgraphgallery.org/Pages/Graph.aspx?graphID=26748" imageanchor="1" style="margin-left: 1em; margin-right: 1em;"><img border="0" height="287" src="https://nodexlgraphgallery.org/Images/Image.ashx?graphID=26748&amp;type=f" width="400" /></a></div><br /><br />I used a Twitter search on the nodeXL Graph Server against the hashtag #5G to select the tweets to study. The messages in the graph were tweeted over a 43 day period in late July and August, 2014.<br /><br />A quick way to see what's been going on is to read the top words in each group label. For example:<br /><ul><li>G1: A 5G network launch in London by 2020 (more about London in G7, G8, G9, ...)</li><li>G2: News about BellLabs/Alcatel-Lucent</li><li>G3: More about Bell Labs, and references to Neelie Kroes and the European Commission&nbsp;</li></ul>To find the most tweeted stories, which usually explain the words in the group labels, scroll down the SNApshot page to the <i>Top Word Pairs in Tweet</i> lists. The most tweeted URL in the entire graph explains the references to 5G in London: it is a <a href="http://www.telegraph.co.uk/technology/news/10994304/5G-in-London-by-2020-pledges-Johnson.html" target="_blank">story in the Telegraph</a>&nbsp;about Boris Johnson's pledge that there would be 5G in London by 2020.<br /><br />It turns out one could pretty much read this off from the list of <i>Top Word Pairs in Tweet in Entire Graph</i>&nbsp;further down the page without even going to the URL:<br /><blockquote class="tr_bq">5g,network<br />network,launch<br />launch,mean<br />mean,consumers<br />5g,london<br />london,2020<br />technology,5g<br />ipod,touch<br />touch,5g<br />5g,mobile</blockquote>The <i>Top Word Pairs</i> are less helpful in figuring out the Bell Labs and EU references in the G2 and G3 group labels. The <i>Top URLs in Tweet in G2</i> provide an explanation: the <a href="http://www.mobileworldlive.com/bell-labs-expert-sees-5g-communications-revolution" target="_blank">first URL</a> in the list on www.mobileworldlive.com reports that a "Bell Labs expert hails future 5G a communications revolution.” The EU mentions turn out to be unrelated (correlation doesn't mean causation!) and are generated by <a href="http://europa.eu/rapid/press-release_MEMO-14-463_en.htm" target="_blank">press</a>&nbsp;<a href="http://ec.europa.eu/digital-agenda/en/news/5g-networks-will-be-leap-not-step-forward" target="_blank">releases</a> about a speech by Neelie Kroes (Vice-President of the European Commission) about 5G.<br /><br />Twitter is all about PR, so this graph reveals which flacks have been earning their keep. Scanning the words associated with the groups reveals they work for Boris Johnson, Bell Labs, Ericsson, Alcatel-Lucent and Neelie Kroes, with honorable mentions for the folks from National Instruments, Nokia, FFTélécoms&nbsp;and the CTIA.<br /><br />To find the most influential twitter users in this area, scroll down the page to the <i>Top 10 Vertices, Ranked by Betweenness Centrality</i> list:<br /><ul><li><a href="https://twitter.com/neeliekroeseu" target="_blank">NeelieKroesEU</a>&nbsp;(Vice President of the European Commission leading Digital Agenda and Connected Continent initiatives)</li><li><a href="https://twitter.com/belllabs" target="_blank">BellLabs</a>&nbsp;(now part of Alcatel-Lucent)</li><li><a href="https://twitter.com/jopocop" target="_blank">jopocop</a>&nbsp;(consultant)</li><li><a href="https://twitter.com/mayoroflondon" target="_blank">MayorofLondon</a>&nbsp;(the ever-tousled Boris Johnson)</li><li><a href="https://twitter.com/trustedreviews" target="_blank">TrustedReviews</a>&nbsp;(news outlet)</li><li><a href="https://twitter.com/ericsson" target="_blank">Ericsson</a>&nbsp;(telecom company)</li><li><a href="https://twitter.com/elenaneira" target="_blank">ElenaNeira</a>&nbsp;(innovator)</li><li><a href="https://twitter.com/kalske" target="_blank">Kalske</a>&nbsp;(Päivi Kalske, marketer at Nokia)</li><li><a href="https://twitter.com/johnbramfeld" target="_blank">JohnBramfeld</a>&nbsp;(sales engineering manager)</li><li><a href="https://twitter.com/telecomasia" target="_blank">TelecomAsia</a>&nbsp;(news outlet)</li></ul>The international character of the topic is shown by the fact that the Top Words on the graph are not only in English:<br /><blockquote class="tr_bq">G10, G13, G15: French<br />G11: Japanese<br />G17: Russian</blockquote>Perhaps the most curious element showed up on the&nbsp;<i>Top Word Pairs in Tweet in G5</i> list:<br /><blockquote class="tr_bq">labview,used<br />used,top<br />top,20<br />20,5g<br />5g,researchers<br />researchers,coincidence<br />coincidence,niweek<br />niglobal,labview<br />5g,wireless<br />wireless,5g</blockquote>What was the coincidence? Looking at the URLs for G5 reveals that "ni" is the measurement company National Instruments (no relation to <a href="https://www.youtube.com/watch?v=zIV4poUZAQo" target="_blank">Monty Python</a>), seller of the LabVIEW software package, and "niweek" is the company's 2014 annual conference. However, the URLs themselves don't point to anything that reveals the coincidence, though there are quite a few National Instruments stories:<br /><ul><li><a href="http://theinstitute.ieee.org/people/profiles/theodore-rappaport-at-the-forefront-of-5g">http://theinstitute.ieee.org/people/profiles/theodore-rappaport-at-the-forefront-of-5g</a> (researcher profile)</li><li><a href="http://www.microwavejournal.com/articles/22894">http://www.microwavejournal.com/articles/22894</a> (announcement of an EU project)</li><li><a href="http://about.keysight.com/en/newsroom/pr/2014/11aug-em14115.shtml">http://about.keysight.com/en/newsroom/pr/2014/11aug-em14115.shtml</a> (press release)</li><li><a href="http://www.rcrwireless.com/20140822/test-and-measurement/niweek-tag6?sf30308412=1">http://www.rcrwireless.com/20140822/test-and-measurement/niweek-tag6?sf30308412=1</a> (coverage of&nbsp;National Instruments’ NIWeek conference)</li><li><a href="http://new.livestream.com/NationalInstruments/events/3225958/videos/58407097">http://new.livestream.com/NationalInstruments/events/3225958/videos/58407097</a> (livestream of a National Instruments event)</li><li><a href="https://www.youtube.com/watch?v=uMTYE4omzkQ&amp;feature=youtu.be">https://www.youtube.com/watch?v=uMTYE4omzkQ&amp;feature=youtu.be</a> (description of a&nbsp;5G mmWave simulator)</li><li><a href="http://www.tumblr.com/Z-r4bp1Mj55mq">http://www.tumblr.com/Z-r4bp1Mj55mq</a> (link to a webcast)</li><li><a href="http://www.ni.com/niweek/rf-summit/">http://www.ni.com/niweek/rf-summit/</a> (National Instruments event announcement)</li><li><a href="http://www.gizmag.com/random-linear-network-coding/33038/">http://www.gizmag.com/random-linear-network-coding/33038/</a> (story about network coding technique that could be used in 5G networks)</li><li><a href="https://decibel.ni.com/content/groups/ni-news-in-real-time/blog/2014/07/28/yonsei-university-joins-rfcommunications-lead-user-program?cid=Social-AT-Corporate-sf29077258">https://decibel.ni.com/content/groups/ni-news-in-real-time/blog/2014/07/28/yonsei-university-joins-rfcommunications-lead-user-program?cid=Social-AT-Corporate-sf29077258</a> (National Instruments press release)</li></ul>To solve the puzzle required digging into the tweet record in the Excel file for the graph (click <a href="https://nodexlgraphgallery.org/Pages/Workbook.ashx?graphID=26748" target="_blank">Download the Graph Data as a NodeXL Workbook</a> at the bottom of the Graph Gallery page; to make best use of the file, one needs to install the NodeXL add-in). The file reveals a tweet originated and promoted by the National Instruments "@labview is used by the top 20 #5G researchers... Coincidence? #NIWeek". So the Graph Gallery doesn't reveal all: sometimes one has to go to the source data.<br /><br />In terms of structure, this graph is a&nbsp;<a href="http://www.pewinternet.org/2014/02/20/part-2-conversational-archetypes-six-conversation-and-group-network-structures-in-twitter/#network-type-4-community-clusters" target="_blank">Community Cluster</a>&nbsp;using the taxonomy of the Pew Research paper&nbsp;<a href="http://www.pewinternet.org/2014/02/20/mapping-twitter-topic-networks-from-polarized-crowds-to-community-clusters/" target="_blank">Mapping Twitter Topic Networks</a>. It shows the characteristic large group of disconnected contributors who mention the topic but do not link to one another (group G1, with about 30% of the vertices), and loosely interconnected sub-groups that focus on subtopics.<br /><br />To get a sense of the structure of the graph, easiest to click on the "<a href="https://nodexlgraphgallery.org/Pages/InteractiveGraph.aspx?graphID=26748" target="_blank">View an interactive version of this graph (experimental)</a>" link that takes one to an X-ray of the graph<br /><br /><div class="separator" style="clear: both; text-align: center;"><a href="http://1.bp.blogspot.com/-ZjDTTeg5iqk/VAJtcHmNLLI/AAAAAAAAAcQ/G9vdIpzmzbQ/s1600/IntvGraph-26748.png" imageanchor="1" style="margin-left: 1em; margin-right: 1em;"><img border="0" src="http://1.bp.blogspot.com/-ZjDTTeg5iqk/VAJtcHmNLLI/AAAAAAAAAcQ/G9vdIpzmzbQ/s1600/IntvGraph-26748.png" height="383" width="400" /></a></div><br /><br /><div class="separator" style="clear: both; text-align: center;"><br /></div>I've color-coded the vertices from blue to red by increasing eigenvector centrality (CITE) and one can see that there's a fair amount of cross-referencing between groups G2, G3, G4 and G6. (Eigenvector centrality highlights users that are well connected to other well-connected users; Activate Networks has a&nbsp;<a href="http://www.activatenetworks.net/who-is-central-to-a-social-network-it-depends-on-your-centrality-measure/" target="_blank">good introduction</a>&nbsp;to centrality metrics.) Interestingly, though, group G5 (the nodes of ni) is disconnected; the National Instruments crowd talked about 5G, but wasn't connected to rest of the conversation.<br /><div></div><br />https://deepfreeze9.blogspot.com/2014/08/5g-on-twitter-nodexl-snapshot.htmlnoreply@blogger.com (Pierre de Vries)0tag:blogger.com,1999:blog-5688599.post-2443929260369685287Wed, 04 Jun 2014 16:20:00 +00002014-06-04T10:17:58.823-07:00adjudicationenforcementfccspectrumAdjudication versus EnforcementMike Marcus (<a href="http://www.marcus-spectrum.com/" target="_blank">web site</a>) has suggested that enforcement problems can be divided into two categories:<br /><blockquote class="tr_bq">#1. Cases where behavior explicitly violates existing rules, e.g. use of the wrong frequency, or equipment that doesn't comply with rules.</blockquote><blockquote class="tr_bq">#2. Unanticipated interactions between systems that either lead to service degradation but do not self-evidently violate any rules, or raise complex legal issues of whether there is a violation.</blockquote><blockquote class="tr_bq">Mike suggests that the second category includes "cellular booster" interference to cellular systems, police radar detector "fuzzbuster" interference to VSATs, the Nextel/public safety intermod problem in 800 MHz, and impairment of 700 MHz cellular due to FM transmitter harmonics (<a href="http://www.marcus-spectrum.com/Blog/files/FM2LTEint214.html" target="_blank">discussed</a> on Mike’s <a href="http://www.marcus-spectrum.com/Blog/Blog.html" target="_blank">blog</a>).</blockquote>The fact that the spectrum community informally refers to both categories as enforcement problems while the second is actually a question of adjudication highlights a problem caused by the FCC’s rudimentary judicial function: while it has more than 250 people in the Enforcement Bureau (<a href="https://apps.fcc.gov/edocs_public/attachmatch/DOC-320096A1.pdf" target="_blank">2014 Budget</a>), it only has <a href="http://www.fcc.gov/encyclopedia/office-administrative-law-judges-staff" target="_blank">one</a> (!) administrative law judge.<br /><br />It seems to me that (1) being clear about the enforcement/adjudication distinction and (2) actually having an adjudication function separate from both rule making (the legislative function) and enforcement (the executive function) would not only help us think more clearly about spectrum problems but would also lead to quicker resolution, to everyone's benefit.<br /><br /><b>Discussion</b><br /><br />As an <a href="http://legal-dictionary.thefreedictionary.com/Administrative+Agency" target="_blank">administrative agency</a> (caveat: IANAL) the FCC combines the three branches of government under one roof: legislative, judicial and executive. It makes rules (legislative), decides whether they have been broken (judicial), and takes action to detect alleged violations, and punish them if violations are found (executive).<br /><br />Mike’s Category #1 (explicit violations of existing rules) is enforcement, <a href="http://www.oxforddictionaries.com/us/definition/american_english/enforcement" target="_blank">defined by the OED</a> as “the act of compelling observance of or compliance with a law, rule, or obligation”: it presupposes that adjudication has already taken place. The examples in Category #2 (unanticipated interactions) are actually questions of adjudication, i.e. “A formal judgment on a disputed matter” <a href="http://www.oxforddictionaries.com/us/definition/american_english/adjudication" target="_blank">per the OED</a>: they're difficult precisely because it's not clear whether there's been a violation, or by whom.<br /><br />The FCC is very loosey-goosey on this distinction, as has been pointed out over the years; see e.g. Ellen Goodman’s 2004 <a href="http://ssrn.com/abstract=484922" target="_blank">Telecosm</a> paper, Phil Weiser’s 2009 <a href="http://ssrn.com/abstract=1336820" target="_blank">FCC Reform</a> paper and our recent Hamilton Project <a href="http://www.hamiltonproject.org/papers/unlocking_spectrum_value_through_improved_allocation_assignment/" target="_blank">paper</a>.<br /><br />Distinguishing clearly between these two categories could also address a blind spot about the need for enforcement in the Dynamic Spectrum Access (DSA) community. If enforcement is addressed at all by advocates of Spectrum Access Systems (SAS), it’s usually waved away with assurances that the rules in the database will solve all problems. (Jerry Park’s <a href="http://wireless.fcc.gov/workshops/sas_01-14-2014/panel-3/Park-VA-Tech.pdf" target="_blank">presentation</a> at the January 2014 FCC 3.5 GHz SAS workshop is an exception, but even he focuses on attacks on the database, rather on how to decide disputes.)<br /><br />Mike's distinction made me realize that the DSA/SAS community probably equates enforcement with Category #1. It's then plausible to believe that a system that prevents explicit rules violations solves, or more accurately obviates, "enforcement problems." However, the arcane interactions between radio systems in the wild and the difficulty in assigning responsibility for them make it important to highlight the Category #2 problems: these unintended issues are not only more likely to cause problems – and cause them unexpectedly – that failures in rule sets, but by their nature they will require judgment (in both a legal sense, and in the sense of requiring assessment of hard-to-compute complexities) to resolve.https://deepfreeze9.blogspot.com/2014/06/adjudication-versus-enforcement.htmlnoreply@blogger.com (Pierre de Vries)0tag:blogger.com,1999:blog-5688599.post-4352185955519488075Sun, 02 Mar 2014 22:29:00 +00002014-03-04T09:18:11.493-08:00modelingpropagationsensorsspectrumterrainRF Mirror Worlds: Supercomputing meets propagation models, 3D terrain data and ubiquitous sensors<a href="http://www.inets.rwth-aachen.de/pma.html" target="_blank">Petri Mähönen</a> has observed that wireless researchers haven’t exploited supercomputing as much as one might expect, especially in comparison with other scientific disciplines such as aerospace, meteorology, oceanography, biology, sociology... If they had, we could be exploring thousands or millions of “Test Cities” rather than just the one contemplated in the PCAST Report (<a href="http://www.whitehouse.gov/sites/default/files/microsites/ostp/pcast_spectrum_report_final_july_20_2012.pdf" target="_blank">pdf</a>, Chapter 6 and Appendix G). The PCAST budget for the first three years of a Test City (Table G.1) runs to $21 million in operating expenses and $15 million in capital expenses – that would buy a lot of computation!<br /><br />I suspect (hope!) we’re on the verge of a step change in using software simulation, aka “mirror worlds”, to understand and manage radio systems. The underlying technology has been on the exponential growth curve we’ve all heard about, but hasn’t broken through to high profile visibility. It may soon.<br /><br /><a name='more'></a><br />David Gelernter’s wonderful “Mirror Worlds: or the Day Software Puts the Universe in a Shoebox” (1993, <a href="http://books.google.com/books?id=jh2U379fq18C&amp;printsec=frontcover&amp;source=gbs_ge_summary_r&amp;cad=0#v=onepage&amp;q&amp;f=false" target="_blank">Google Books</a>) postulated capturing extensive data about a particular “reality” (hospital, city, etc.) and then presenting a constantly updated model of that reality on a desktop computer:<br /><blockquote class="tr_bq">“They are software models of some chunk of reality, some piece of the real world going on outside your window. Oceans of information pour endlessly into the model (through a vast maze of software pipes and hoses): so much information that the model can mimic the reality’s every move, moment-by-moment.</blockquote><blockquote class="tr_bq">“A Mirror World is some huge institution’s moving, true-to-life mirror image trapped inside a computer—where you can see and grasp it whole. The thick, dense, busy sub-world that encompasses you is also, now, an object in your hands.”</blockquote><blockquote class="tr_bq">(Mirror Worlds, Ch. 1, p. 3)</blockquote>This image has stayed with me. We’re not quite there yet, but Mirror Worlds may well have inspired work on radio environment maps and spectrum management databases, in the same way that Star Trek inspired the smartphone: people are talking about Dynamic Spectrum Access databases as a way to manage wireless sharing by creating an accurate model of the real world radio environment.<br /><br />Moore’s Law has been chugging for decades, and has given us pocket supercomputers (aka smartphones) and Big Data. Given the accelerating shift in radio technology from analog to digital, radio systems are surfing this wave, too, and it feels as if we’re on the threshold of major change. The spectrum landscape will be seen through a software lens 5-10 years from now: the RF (radio frequency) Mirror World.<br /><br />I think of the engine of the RF Mirror World &nbsp;as having three interlocking components:<br /><br /><ol><li>Propagation models</li><li>Terrain models</li><li>Sensors</li></ol><br />Propagation models predict the resulting signal strength at any location given the location and characteristics of transmitters, and the intervening obstacles encoded as terrain models. Propagation predictions have to be calibrated to reality, though (typical model errors are ~ 9 dB, per <a href="http://dx.doi.org/10.1109/DYSPAN.2011.5936271" target="_blank">Phillips, Sicker &amp; Grunwald</a>); ubiquitous cheap sensors can provide ground truth. Each of these fields has been developing rapidly; when knitted together, the whole could be transformative.<br /><br /><b>1. Propagation models</b>. I'm very ignorant here, but my guess is that while the models themselves are pretty well understood, computer run-time and terrain/obstruction data is the binding constraint. This will inevitably be solved by a combination of Moore’s Law and algorithm development. Wireless planning software suites like <a href="http://www.edx.com/products/all-products.html" target="_blank">EDX</a> SignalPro already do very sophisticated calculations, and operators are combining them with measurement to improve coverage predictions. Such tools are already integrated with 3D models (see #2 below);&nbsp;Here's a screenshot from the Google Earth Plug-in EDX for SignalPro V8.1:<br /><br /><div class="separator" style="clear: both; text-align: center;"><a href="http://2.bp.blogspot.com/--93koJ4mNXA/UxPq8ATFzFI/AAAAAAAAAaE/9tlVmQDxc2I/s1600/SignalProGoogleEarth.png" imageanchor="1" style="margin-left: 1em; margin-right: 1em;"><img border="0" src="http://2.bp.blogspot.com/--93koJ4mNXA/UxPq8ATFzFI/AAAAAAAAAaE/9tlVmQDxc2I/s1600/SignalProGoogleEarth.png" height="201" width="320" /></a></div><br />Uncertainties remain due to weather (snow cover), season (vegetation), and human activity (aluminum semi-tractors trailers), but one can imagine that they could be compensated for dynamically using&nbsp;with real-time closed-loop calibration of propagation models using data from ubiquitous sensors. In fact, sensing &amp; modeling done over a wide frequency range could help discriminate among features of different scales, e.g. leaves vs. people vs. semi-trailers, since scattering depends on the size of the scatterer.<br /><br /><b>2. Terrain models</b>. Many propagation models assume generic terrain, like “small city” or parameters for average building height and separation. More accurate models that trace real-world propagation paths need data on terrain. Terrain models are becoming increasingly accurate, even to the point of becoming topics of regulatory dispute; for example, the FCC has <a href="http://apps.fcc.gov/ecfs/document/view?id=7022117218" target="_blank">proposed</a> replacing a terrain database with 300 foot resolution with a 100 foot one. More striking is the resolution of 3D city models being used in <a href="http://appleinsider.com/articles/13/07/31/apples-ios-7-3d-maps-leave-google-earth-nokia-3d-maps-looking-old-fashioned" target="_blank">Apple</a> and Google maps. CyberCity3D provides maps to Google, and <a href="http://www.cybercity3d.com/newcc3d/index.php/technology/item/156-workflow" target="_blank">boasts</a> of up-to-six inch accuracy in its textured city models; here's an image from their Facebook <a href="https://www.facebook.com/CyberCity3D" target="_blank">page</a>:<br /><div class="separator" style="clear: both; text-align: center;"><a href="http://2.bp.blogspot.com/-no6XLud4dxE/UxOzbLO-57I/AAAAAAAAAZw/IGFsxgF_SXg/s1600/cybercity3d.jpg" imageanchor="1" style="margin-left: 1em; margin-right: 1em;"><img border="0" src="http://2.bp.blogspot.com/-no6XLud4dxE/UxOzbLO-57I/AAAAAAAAAZw/IGFsxgF_SXg/s1600/cybercity3d.jpg" height="146" width="400" /></a></div><br />That’s getting to the point where one can really do pretty snazzy ray tracing propagation for outdoor scenarios. One can even dream about simulating vehicles and people in the mirror world – in many cities, we now have almost-real-time traffic data at street level. &nbsp;This doesn’t address the indoor case directly, but with enough processing power and measurements I can imagine AI that infers and updates architecture, wall loss etc. by constantly running models against measurements as people move their devices around inside buildings.<br /><br /><table align="center" cellpadding="0" cellspacing="0" class="tr-caption-container" style="float: right; margin-left: 1em; text-align: right;"><tbody><tr><td style="text-align: center;"><a href="http://3.bp.blogspot.com/-UiY8WLsg3xU/UxOuofWImqI/AAAAAAAAAZQ/LckcXZdAerw/s1600/HP8566B.jpg" imageanchor="1" style="margin-left: auto; margin-right: auto;"><img border="0" src="http://3.bp.blogspot.com/-UiY8WLsg3xU/UxOuofWImqI/AAAAAAAAAZQ/LckcXZdAerw/s1600/HP8566B.jpg" height="125" width="200" /></a></td></tr><tr><td class="tr-caption" style="text-align: center;"><span style="font-size: small; text-align: start;">HP8566</span></td></tr></tbody></table><b>3. Sensors</b>. Understanding the radio environment is all about sensors and data integration. The cost of measurement is coming down dramatically; spectrum analyzers are mostly just computers, and benefit from Moore’s Law just like everything else. For example, a retired executive at a measurement company has told me that in 1980, the HP8566 cost $75K and weighed about 85 lbs, while today’s Agilent FieldFox N9938A costs about $35K and weighs 6.6 lbs—the basic RF performance of the two products is about the same.<br /><br /><table align="center" cellpadding="0" cellspacing="0" class="tr-caption-container" style="float: right; margin-left: 1em; text-align: right;"><tbody><tr><td style="text-align: center;"><a href="http://1.bp.blogspot.com/-47NaM81Pr1c/UxOuqkGk11I/AAAAAAAAAZY/coBj-zxzj8s/s1600/AgilentFieldFox.jpg" imageanchor="1" style="margin-left: auto; margin-right: auto;"><img border="0" src="http://1.bp.blogspot.com/-47NaM81Pr1c/UxOuqkGk11I/AAAAAAAAAZY/coBj-zxzj8s/s1600/AgilentFieldFox.jpg" height="166" width="200" /></a></td></tr><tr><td class="tr-caption" style="text-align: center;"><span style="font-size: small; text-align: start;">Agilent FieldFox N9938A</span></td></tr></tbody></table>The number of “spectrum observatories” going to climb dramatically, from a handful around the world five years ago, to dozens today, and hundreds if not thousands in a few years. In terms of more limited band-of-operation measurement, tens of millions of LTE handsets are already capable of making spectrum measurements today with mass deployment to come as part of the “<a href="http://telecomfunda.com/forum/showthread.php?29130-What-is-MDT" target="_blank">Minimization of Drive Tests</a>” feature in 3GPP cellphone specs. DARPA’s <a href="http://www.darpa.mil/Our_Work/STO/Programs/Advanced_RF_Mapping_(Radio_Map).aspx" target="_blank">RadioMap</a> research program has staked out the vision, seeking to “provide real-time awareness of radio spectrum use across frequency, geography and time … in part by using radios deployed for other purposes, like data and voice communications systems.”<br /><br /><i>Of course, by the "If I can think of something, someone's already done it" Rule, it's a safe bet that my speculations have already come true. But even if today's reality is more advanced than I think, that still leaves the challenge of figuring out what the world will be like in five and ten years time, and what impact that will have on business, engineering and public policy.</i>https://deepfreeze9.blogspot.com/2014/03/rf-mirror-worlds.htmlnoreply@blogger.com (Pierre de Vries)1tag:blogger.com,1999:blog-5688599.post-8844999729522564304Sat, 22 Feb 2014 22:18:00 +00002014-02-22T15:34:19.261-08:00DoDmetaphorsharingspectrumDoD treats Spectrum as TerritoryThe U.S. Department of Defense released a spectrum strategy document on Thursday (<a href="http://www.defense.gov/Releases/Release.aspx?ReleaseID=16547" target="_blank">press release</a>, <a href="http://www.defense.gov/news/dodspectrumstrategy.pdf" target="_blank">pdf</a>). I’ll leave discerning what (if anything) is actually new in it to the Pentagon watchers.<br /><br />I was struck by the implications of the language used: the DoD conceives of spectrum as a place. Given that military success often seems to be framed as controlling or denying territory, this is not an auspicious starting point for spectrum sharing – which is about wireless system coexistence in many intangible dimensions, rather than all-or-nothing control of territory.<br /><br /><a name='more'></a>A quick look at the language of the text leaves no doubt that spectrum is seen as a field ("<a href="http://dictionary.reference.com/browse/field" target="_blank">an expanse of open or cleared ground</a>") of battle:<br /><blockquote>“Electromagnetic spectrum (EMS) <b>access</b> is a prerequisite for modern military operations.”</blockquote><blockquote>“… adversaries [are developing] technologies that significantly reduce the ability of DoD to <b>access</b> the spectrum and conduct military operations.” </blockquote><blockquote>“DoD recognizes that the electromagnetic <b>environment</b> (EME) will be increasingly <b>congested and contested</b> wherever military operations occur.”</blockquote><blockquote>“<b>Like air, space, land, </b>maritime, and cyberspace domains, military <b>forces maneuver within the [electromagnetic spectrum]</b> to gain tactical, operational, and strategic advantages.” </blockquote><blockquote>“DoD operations – in the air, on land, on and under the sea, in space, and in cyberspace – are fundamentally dependent on our <b>use and control</b> of the electromagnetic spectrum.”</blockquote>The underlying metaphor is that spectrum is a place, and that radio operation requires access to, and control of, that place. In the military context, especially, that evokes images of territorial dominance and exclusion.<br /><br />However, radios coexist in much more complex and flexible ways than soldiers and civilians on a battlefield. To take a simple example, <a href="http://en.wikipedia.org/wiki/Spread-spectrum" target="_blank">spread-spectrum</a> technology allows a number of radio systems to operate concurrently in the same time, frequency and geographic area, each looking to the other like background noise.<br /><br />Spectrum-as-place is just a metaphor and as I argued in DySPAN papers in 2007 (<a href="http://dx.doi.org/10.1109/DYSPAN.2007.55" target="_blank">IEEE</a>, <a href="http://ssrn.com/abstract=965477" target="_blank">SSRN</a>) and 2008 (<a href="http://dx.doi.org/10.1109/DYSPAN.2008.63" target="_blank">IEEE</a>, <a href="http://ssrn.com/abstract=1241342" target="_blank">SSRN</a>) not the only or even the best one.<br /><br />The ostensible meaning of the DoD strategy document would be unchanged if the spectrum-as-place language were replaced by the language of spectrum-as-radio-operation, e.g. replacing “to access spectrum” by “to use radios.” (See also my 2009 post <a href="http://deepfreeze9.blogspot.com/2009/09/no-more-s-word.html" target="_blank">No more S-word</a>).<br /><br />However, the subliminal guidance to DoD staff would be very different if this change were made, particularly when it comes to radio coexistence: radio operation may be a much more productive way of talking about “spectrum sharing” for soldiers to whom sharing a battlefield with someone not under their control is likely to be a rather uncomfortable notion.<br /><br />(Left as an exercise for the reader: Doing a similar analysis for DoD doctrine about cyberspace, which is really not very spatial either… )<br /><div><br /></div>https://deepfreeze9.blogspot.com/2014/02/dod-treats-spectrum-as-territory_22.htmlnoreply@blogger.com (Pierre de Vries)0tag:blogger.com,1999:blog-5688599.post-5369674061814475508Wed, 16 Oct 2013 16:13:00 +00002013-10-16T09:15:38.806-07:00regulationspectrumunlicensedUnlicensed’s success: physics, not regulation?Unlicensed allocations have generated a massive, and to many surprising, amount of innovation and value (see the References below). The question is: Why?<br /><br />Almost all of the value so far has come in the 2.4 GHz ISM band, mostly due to Wi-Fi but also to a lesser extent Bluetooth applications. There is never a single, simple answer to a Why question about a complicated nexus of technology, politics and user behavior, but my impression is that unlicensed partisans believe that it's due pretty much exclusively to the techno-economic characteristics enabled by the rights assignment regime: “openness” (<a href="http://cyber.law.harvard.edu/publications/2012/unlicensed_wireless_v_licensed_spectrum" target="_blank">Benkler</a>), “managed commons” (<a href="http://ssrn.com/abstract=1948257" target="_blank">Milgrom, Levin &amp; Eilat</a>), or “rule-based access” (<a href="http://research.microsoft.com/en-us/projects/spectrum/case-for-permissive-rule-based-dynamic-spectrum-access_thanki.pdf" target="_blank">Thanki</a>).<br /><br />I think it's at least plausible that Wi-Fi's undoubted success has been due to a fortuitous coincidence of band choice, physics and timing as much as to regulation: It turned out that the interference range was small enough that users didn’t really degrade each other’s performance; and the networking needs of their applications could be met by the bandwidth available around them. In other words: the capacity of the channel was larger than the number of people who interfered with each other, multiplied by the data they wanted to move.<br /><br /><a name='more'></a><br />Some key factors were:<br /><br /><ul><li>The combination of 2.4 GHz operating frequency and indoor use limited interference between Wi-Fi access points;</li></ul><ul><li>The dominant application was multi-media web browsing, which provides excellent user value but is tolerant of some loss and delay;</li></ul><ul><li>The 3 x 22 MHz bandwidth enabled by the 84 MHz allocation was sufficient to support these kinds of broadband for users within the interference range, in most cases.</li></ul><br />Other things also helped:<br /><br /><ul><li>The cost of Wi-Fi infrastructure was largely invisible: consumers bought boxes for home networking, and increasingly got them “free” as part of cable and telco broadband routers; Wi-Fi was deployed as must-have amenities (like restrooms) in public venues;</li></ul><ul><li>The high volume and relative simplicity of Wi-Fi components meant they were cheap, and became ubiquitous, feeding a virtuous cycle;</li></ul><ul><li>The explosion in demand for mobile data enabled by the iPhone phenomenon – emerging from the licensed, not unlicensed, ecosystem – could leverage the installed base of Wi-Fi access points in homes and public venues;</li></ul><ul><li>IEEE 802.11 and the Wi-Fi Alliance emerged as de facto band managers, as argued in David Reed and Jim Lansford's <a href="http://ssrn.com/abstract=2238158" target="_blank">2013 TPRC paper</a>.</li></ul><br />To the extent that unlicensed’s success is due to the particularities of indoor use at 2.4 GHz of multi-media web pages, rather than “commons” allocation, the success in this band won’t necessarily follow automatically elsewhere, e.g. in the TV bands where interference ranges are much larger; for use in outdoor wide area coverage, as contemplated by the cable industry (remember ill-fated Muni Wi-Fi?); or as much more demanding applications like streaming HD video become dominant. However, it is likely that unlicensed will grow from strength to strength in bands and venues where the interference range is small and allocated bands are wide, e.g. 5 GHz and above.<br /><br />I suspect the wild success of cellular-like licenses is also due to some fortunate coincidences (including the success of unlicensed), but that’s a topic for another post.<br /><br /><b>References</b><br /><br />Some recent paeans to unlicensed:<br /><blockquote class="tr_bq">Benkler, Y. (2012). Open wireless vs. licensed spectrum: Evidence from market adoption. Harvard Journal of Law and Technology, 26(1). <a href="http://cyber.law.harvard.edu/publications/2012/unlicensed_wireless_v_licensed_spectrum">http://cyber.law.harvard.edu/publications/2012/unlicensed_wireless_v_licensed_spectrum</a></blockquote><blockquote class="tr_bq">Milgrom, P. R., Levin, J. D., and Eilat, A. (2011). The case for unlicensed spectrum. Google. <a href="http://ssrn.com/abstract=1948257" target="_blank">http://ssrn.com/abstract=1948257</a></blockquote><blockquote class="tr_bq">Thanki, R. (2013). The case for permissive rule-based dynamic spectrum access. Microsoft. <a href="http://research.microsoft.com/en-us/projects/spectrum/case-for-permissive-rule-based-dynamic-spectrum-access_thanki.pdf">http://research.microsoft.com/en-us/projects/spectrum/case-for-permissive-rule-based-dynamic-spectrum-access_thanki.pdf</a></blockquote>This thinking has been was heavily influenced by Doug Sicker et al.'s 2006 TPRC paper that used a combination of US population density analysis and system performance simulation to argue that given a 56 m interference radius and 3 Wi-Fi channels, 90% of population was within interference range of fewer than 20 other people – and that web browsing or VOIP only break down for more than 20 users<br /><blockquote class="tr_bq">Sicker, D., Doerr, C., Grunwald, D., Anderson, E., Munsinger, B., and Sheth, A. (2012). Examining the wireless commons. In&nbsp;<i>TPRC 2006</i>.&nbsp;<a href="http://ssrn.com/abstract=2103824" target="_blank">http://ssrn.com/abstract=2103824&nbsp;</a></blockquote><br /><br />https://deepfreeze9.blogspot.com/2013/10/unlicenseds-success-physics-not.htmlnoreply@blogger.com (Pierre de Vries)0